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3.7 Commendable Activities <br />Bar-D is the only pit that has consistently provided cross sections and longitudinal <br />profiles at a standard scale, with current data superimposed on data for previous years. <br />Both operators should be commended for limiting thalweg incision to date at the <br />upstream boundary and in some parts of the pit. Incision as great as 6 ft is technically <br />allowed under the amended permit, but would have a huge impact on adjacent properties <br />that aze located upstream along either the Animas River or Hermosa Creek. <br />FCMI has begun collecting survey and other data at cross sections extending from the <br />Bakers Bridge area to Hermosa Meadows (Paul Sugnet to Lesley McWhirter, 11/12/02). <br />Eventually, this study will provide valuable information for river management. <br />4.0 DALTON PIT <br />4.1 Operator <br />• Sandco, Inc. (since before 1996) <br />4.2 Changes to Permit Special Conditions <br />Proposed Monitoring and Riparian Enhancement Prog am <br />Before USACE finalized the text of the permit, Sandco, Inc. submitted a consultant's report that <br />outlined a comprehensive plan for monitoring, data analysis, and riparian enchancement <br />(Lidstone & Anderson, 1996). Sandco voluntarily committed to implement the suggestions and <br />recommendations in that report not only at the Dalton Pit, but also at the Hermosa Meadows Pit <br />(David Dillon to Ken Jacobson, 8/25/96). Key provisions included: <br />• Surveying all cross sections each fall and assessing inter-annual changes <br />• Collecting gravel samples and measuring their component particle sizes <br />• Recording and photographing riverbank conditions, vegetation, wildlife, and habitat <br />• Preparing a comprehensive 5-year report to address changes in channel geometry (natural <br />and man-induced), sediment supply, and mining sustainability <br />• Enhancing habitat by using fish- and wildlife-friendly bank-stabilization methods <br />wherever possible <br />So far as I know, USACE never acknowledged this report, and it was not formally incorporated <br />by reference into the approved monitoring plan (unlike Sugnet & Associates' 1996 report for <br />Bar-D). Possibly neither USACE nor Sandco thought in 1996 that formal reference was needed, <br />as Sandco had voluntarily agreed to perform these activities. Sandco clearly submitted the report <br />and made this commitment to favorably influence USACE's permit decision and conditions, so it <br />is reasonable to evaluate whether Sandco implemented the report's proposals. <br />Gillam to Hellige, Nov. 28, 2003 page 8 <br />