Laserfiche WebLink
as serious and long lasting ~ose made by Dalton Ranch. • <br />Although I realize that many issues of use in the River may be the responsibility of other <br />governmental agencies, the Corps is normally turned to as the authoritative permiuer and <br />seldom will local agencies become involved, even if empowered, if there has been Corps <br />review. This, as a result, lays the responsibility For evaluation of the effect of extraction nn <br />the Animas River directly on the Corps shoulders. The Corps has the expertise and staFf to <br />evaluate what is best for the riverine environment better than any other agency. <br />I think there is no question that this renewal time is the prime opportunity for the Corps to <br />re-evaluate "business as usual" on the Animas River. It is my understanding that the Carps <br />now has increased regulatorypower over both fill and removal operations below the OH W. <br />You certainly indicate on Page 4 of the permits, in your third paragraph, that you are fully <br />aware of the problems and the need Eor study of them. It should not be "dijjicul.r ro obraiit <br />full pnrricipnriat artd jtutding from rite Animas River operators", as you state, if it becomes <br />a condition of their permit approval. I would like the Corps to examine thz 'following, either <br />itself, or through requirements placed on the pit operators: <br />1. Develop a methodology for coordinating Corps activities with FEMA activities. La Plata <br />County has not been pro-active in enforcing existing tloodplain regulations that they have <br />on the books. This is often because not enough guidance has come from the (:orps and <br />FEMA. Substantial riverchannel modifications occur with no FEMA or tloodplain permitting <br />action whatsoever. <br />2. Monitorpast grave] extraction activities and attempt to reconstruct their year by }~eareftect <br />on the riverbed and Riparian areas. This should be possible through archival air photographs <br />and narrative interviews with property owners. <br />3. Establish where future threats lie to the remaining Riparian, wetland and riverbed systems <br />through hydraulic analysis, biological investigation, and other use of specialists than can <br />construct a reliable scenario. <br />4. Construct a baseline of river elevations, riparian areas, extent of river channel, locations <br />of wetlands, than can be used in the future to determine the viability of any restrictions or <br />guidance placed upon the extractors. <br />It is obvious that the Corps has allowed all of these permits to expire at the same time in <br />order to provide an opportunity to take a serious look at river impacts. The Corps would be <br />seriously remiss if the permits were reissued with no substantive change in operator <br />restrictions. <br />Thank yoit very much, <br />~-- <br />Oap Allen <br />April 9, 1996 <br />