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<br /> <br />Page 2 <br />Proper containment and disposal of mine and plant generated chemicals or <br />other toxic by-products are essential to ground water protection. These <br />containment and disposal plans must be detailed prior to granting permit. <br />- Flood Protection <br />This proposed mine site is entirely within the 100-year flood plain for the <br />South Platte. The application should provide a detailed plan of operation which <br />will protect adjacent and downstream residents from mine or plant produced <br />effluent in the event of periodic flooding of the adjacent South Platte River. <br />Wetlm:ds and Wildlife Hnbitat <br />The application should provide a site specific review and identification of <br />jurisdictional wetlands prior to granting permit. This study should be <br />undertaken by a neutral third party agency. The tnie and full adverse impact of <br />this mining and industrial processing operation on critical wildlife habitat <br />contained within the permit area should be fully evaluated by a neutral third <br />party agency. <br />Bonding <br />Given the applicant's lack of prior experience in the extraction of sand and <br />gravel, it is important that the corporation's liability be confirmed. In reviewing <br />[his permit we ask the Board to consider the maximum amount for posting of <br />the required reclamation bond. <br />Second, [he proposed Reclamation Plan does not reflect current benchmark practice <br />and state-of--the-art design for mined land reclamation. The water which would be <br />required for augmentation of the evaporative loss from the lake surfaces in this <br />reclamation plan is significant. This water is currently available for agriculture <br />production and it would be lost for such purpose in perpetuity. This loss of agriculture <br />water is not compatible with Weld County's Comprehensive Plan. <br />Third, the proposed mine site includes two historical sites that ]lave major <br />significance for Weld County and the State of Colorado. The n~ins of the Fort St. Vrain <br />Trading Post, circa 1838 (site 5 WL814 of the Colorado Historical Society), is being listed <br />on the State Register of Historic Places. The site is also eligible for registry on the <br />National Register of Historic Places. It is a critical archeological treasure which is <br />irreplaceable and singular in its significance. The application fails to acknowledge this <br />conflict and does not address any detailed plan of protection/mitigation for these sites. <br />The application does state that a 200-foot setback would be maintained around the <br />present location of the historical marker for Fort St. Vrain. However, the original trading <br />post site is not represented by the marker location. This original site can only be <br />determined with expert archeological assistance from The Colorado Historical Society. <br />Appropriate protection for the original site must then be outlined in the mine permit <br />application. <br />