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• ~ge 4 <br />June 18, 1985 <br />Sand Pit <br />C. Farrell <br />Item 6: As noted in Mike Stanton's June 9, 1982 Inspection Report, <br />steep highwalls were present on site. His suggestion of mining benches <br />to promote stability, and facilitate reclamation (backfilling) is <br />reiterated. Please respond. <br />RESPONSE: Mr. Stanton's suggestion was considered, but the <br />loss in mineral resources was far too great to utilize such an approach. <br />In so far as safety is concerned, there has never been a problem <br />expressed by any safety inspectors regarding working the sand deposit in <br />this fashion. Stability is somewhat a different matter, but there are <br />several ways to promote final stability in a mined slope. In this <br />material which is a sharp sand of very consistent sized particles, even <br />rather steep slopes can be quite stable. <br />We agree that using a bench approach might facilitate reclamation <br />to some extent, but the legislative declaration of this act as well as <br />its predecessors are clear that mining and reclamation are both <br />necessary and compatible. Whether this slope is reclaimed by means of <br />benching or backfilling seems to be of little importance so long as the <br />plan is implemented and the legislative intent of the applicable laws <br />are fulfilled. It seems to us that the loss of perhaps a million cubic <br />yards of sand just to reclaim it according to one of several <br />' satisfactory ways is not a wise use of natural resources, especially <br />when other approaches can allow us to have the sand and suitable <br />reclamation at the same time. <br />Exhibit E - Reclamation Plan <br />Item 1: If the site is not reclaimed for commercial development, <br />please commit to smoothly grading the 8 to 12 feet "stair-step pattern" <br />to simulate "continuous yet undulating" natural topography. Will the <br />slopes be planar or undulating? <br />~~ RESPONSE: Smoothly grading the slope and connecting it to the <br />y slopes in the Daniel's Sand Pit #2 area would not be wise, that is, if <br />it were truly planar. Such slopes, unless virtually level, are <br />notorious for creating erosion and runoff problems. By producing a <br />~ slight stairstep pattern water falling on the site is more likely to <br />'stay there and do the revegetation some good rather than running off and <br />~l eroding a streambank somewhere. In fact, streambank erosion on <br />O Fountain Creek has become a very severe problem primarily because <br />developers do not allow for on-site, temporary retention or utilization <br />of rainfall. Furthermore, the local governments do not seem to even <br />encourage such retention. In our opinion, it is better to have a slight <br />stairstep pattern and retain some water than to produce a planar surface <br />that requires expensive and complex drainage systems that invariably <br />require long term maintenance to make them work and keep working. <br />~o <br />W <br />