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~ -. <br />III ~II~I~~II~~II III <br />Lloyd V. "Buck" Barnhart <br />;imxnxarrx~~rk ~ Pueblo, Colorado 81001 I (303) 542-9207 <br />3 Sedum Court Office 543-1324 <br />October 16, 1980 <br />Colorado Division of Wildlife <br />Gunnison Station <br />P.O.Box 868 <br />Gunnison, Colorado 81230 <br />Re: Va1coJGunnison <br />Vader 6 Rozman Pits <br />Gentlemen <br />September 12, 1980 I submitted "Request for Information" forms on these <br />two pits. The information is required by the Mined Land Reclamation Board <br />for permit processing. <br />I understand that when Tom Henry visited the Vader Pit there was some <br />concern on his part about the method of operation and possible need for a <br />Corps of Engineers 404 Permit. The Vader Pit is already a permitted pit by <br />the Mined Land Reclamation Board. It was permitted as the Signal Peak Ranch <br />gravel operation, Pile No. 78-287. Recently VALCO purchased this pit from <br />Signal Peak Ranch Co. The permit application I refer to is to change the <br />presented Limited Impact Permit (110) to a Regular Permit (112). <br />The stripping operation that was being performed to open up the pit for <br />spring was in compliance with the existing permit. Exhibit "B" of the permit <br />states: <br />"A crusher will be installed at the southernmost portion of the <br />gravel pit and will proceed in a generally northwesterly direction". <br />This is exactly what VALCO was doing except the crusher had not been moved in. <br />The concern about a 404 Permit is a little surprising. VALCO has many years <br />experience in the business and is entirely aware of permit procedures and <br />requirements. They also realize the difference between floodplain areas <br />and wetlands. Ploodplains do not require a 404 permit but wetlands do. It <br />is my opinion, the applicant's and SCS that this is a floodplain area and <br />not Wetlands. <br />The Corps of Engineers Permit Program Guidelines defines Wetlands as: <br />" Those areas that are inundated or saturated by surface or ground <br />water at a frequency and duration sufficient to support, and <br />that under normal circumstances do support, a prevalence of <br />vegetation typically adapted for life in saturated soil conditions. <br />Setlands generally include swamps, marshes, bogs and similar <br />areas." <br />The SCS report on this site classifies the area as Irim loam, 0 to 1 per- <br />cent slope. Excerpts from the report state: <br />"This soil is on floodplains adjacent to major streams and side <br />drainageways. A11 the acreage is irrigated and used for hay." <br />Their classification of the site is hay meadow. Obviously this is not <br />