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JUN-29-94 WED 15;24 CITY BOULDER OS/RE FAX N0, 3034429 <br />P, 04 <br />The present surface water hydrology plan is to retain all nmoff in the pit sites until the mined lands <br />have been n:vegetated. The existing riparian azeas will not survive this disniption of their water <br />regime. Sui.-face runoff should be not retained. Instead, it should be released at historic rates and <br />locations aft+:r each storm event to support these riparian areas. <br />Grou ndwater- <br />With the present mining plan to excavate to the top of the bedrock (pierre shale), this will evaporate <br />any groundwater or vadose water. (Augmentation water should be provided to replace this evaporated <br />subsurface water.) The ripazian plants will not survive this undercutting of this water system. There <br />are also existing wet areas, seeps, along all these valleys. Undercutting or dewatering by mining will <br />destroy these seeps and their native ripazian areas. A plan to prevent the disruption of groundwater <br />flow to the present riparian azeas should be developed prior to approval of this application. <br />Groundwater Contamination Testing <br />The application needs to update the available information concerning groundwater contamination in the <br />application area. The application only referred to 1991 Rocky Flats Plant groundwater testing. No data <br />was made available of these tests or other updated testing for our review. <br />Proposed Reclamation Seed Mix <br />The proposed seed mix is generally good, but we would request the following changes be made: <br />Eliminate the forbs species from the seed mix until after grass has become established in the <br />area. A noxious wed problem is already present; if herbicides are used, then the forb <br />component is likely to be lost anyway. Forbs can always be added to the azea later. The one <br />exception that might be considered is anitrogen-fixing native legume if soil 'N' is a problem. <br />Eliminate Poa pratensis and Poa compressa from the seed mix. These are weedy species that <br />will show up anyway. Substitute needleandthread, green needlegrass, mountain muhly, and <br />junegrass, and boost the amount of western wheatgrass and little bluestem. <br />We appreciate this opportunity to review the application material and provide to you our comments and <br />concerns. ]3owever, the Boulder Open Space Staff will be recommending to the Open Space Board <br />of Trustees and the Boulder City Council that we should oppose this mining application for the reasons <br />outlined above. <br />Sincerely, <br />lenn D. Ca~rriere, P.E. <br />Project Manager <br />ce: Jim Crain, Director <br />Delart: Wheeler, Deputy Director <br />Tamar a Nauman <br />Cindv Owsley, Boulder County Pazks and Open Space <br />