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~ ~ iii iiiiuiiiim iii <br />OFFICE OF COMMUNITY DEVELOPMENT <br />City of 1100 10TH STREET, GREELEY, COLORADO 80631 (970) 350-9780 FAX (g70) 350-9800 <br />Greeley <br />December 8, 1999 DECEIVED <br />Carl B. Mount <br />Senior Environmental Protection Specialist <br />State of Colorado <br />DEC 1:; 1SS9 <br />l~vis~on of iJ~~nerats & Geology <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Ref: Permit #M-99-098 <br />Deaz Mr. Mount: <br />The City of Greeley provides the following comments regarding the reclamation permit <br />application referenced above and submitted by CAMAS Colorado, Inc. I[ should be noted that <br />the landowner of the portion of the site south of the Poudre River has offered the property to the <br />City as open space. Therefore, the City has an interest in~this project beyond that of potential <br />impacts io adjoining lands within the city limits. <br />WILDLIFE HABITAT ISSUES: This project is proposed in an area designated as "High Impact" <br />in the City's Areas of Ecological Significance which also corresponds to habitat information <br />provided to Weld County by the Colorado Division of Wildlife. Throughout the project narrative, <br />references are made to "preserving" or improving wildlife habitat. It needs to be understood that <br />a number of existing habitat areas will be destroyed. "Restoration plans" for the designated <br />"wildlife habitat restoration azea" are sketchy. "Water storage lakes or ponds" have historically <br />been shown to rot be of much value to wildlife other than as temporary locations for some <br />waterfowl since water levels may be drawn down generally throughout the summer during <br />important nesting and spawning times. Without appropriate shoreline habitat improvements, the <br />lakes themselves have little habitat value. Cell 1 is referenced as not being "lined". There is no <br />other reference to lining the other cells other than by inference as "storage". Lined lakes may <br />have even less aquatic habitat value since water tends to stagnate more. <br />The proposed reclamation plan will "replace" existing terrestrial wildlife habitat with large water <br />bodies with limited habitat for birds, mammals, and fish unless standards are implemented that <br />create more shoreline including "bays" with shallow water areas and islands within the lake <br />bodies. Slopes along lakes, especially Cell 1 should be finished at 5:1 or gentler. Because Cell 1 <br />is an unlined lake and will require augmentation, efforts should be made to reduce surface azea to <br />the greatest extent possible. This will, in turn, help create more usable habitat areas. The City of <br />Fort Collins has completed a study, funded in part by Great Outdoors Colorado, that gives <br />