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(~jrour~WQ.ly~./Co 4{ehwao~ S June 4, 2001 To: County Commissioners From: Loretta Van Norstrand On behalf of area residents RECEIVED JUN 1 4 2001 Division of Minerals and Caalopy Visual screening and noise mitigation issues as stated in the Routt County Zoning Resolution have not been adequately addressed. The applicant's floodplain report and traffic issues still must be seriously addressed. The Jord Gerdson report, commissioned by the County, does not outline correct mitigation to maintain the cottonwood screen to comply with the visual, noise and wildlife habitat preservation that Routt County's Zoning Resolution requires. There is simply not evidence to support Gerdson's conclusions. The report does not supply County Commissioners with an adequate record upon which to base a decision; therefore, any decision rendered on this study alone would be arbitrary and capricious. The Routt County Zoning Resolution states, "Such uses must comply with the following: 8.3.1 C item 4 "Shall mitigate visual and scenic quality impacts. " 8.3.1 C item 6 "Shall mitigate potential negative effects to wildlife and wildlife habitat. " 8.3. / C item 9 "Shall be compatible with surrounding agricultural, residential, and recreational land uses by selection of location and/or mitigation. " Although John Eastman is so fond of telling us the Planning Department cannot discuss alternate locations with Mr. Camilletti, item 9 suggests that he is not being truthful. The Zoning Resolution stipulates criteria to be used as tests for compatibility (8.3.1.3-D (2 C). This criteria states, "The mining site will not be visible to adjacent or surrounding residences or will be mitigated to the extent reasonably passible, ... to have reduced visibility. Placement of the operation a sufficient distance from public roadways, behind natural landforms and existing major vegetation, ... will minimize visual contact. " It should be noted that Commissioner Diane Mitsch Bush, Commission Vice Char, indicated the above items in the Zor>ing Resolution were reasons that she voted against the Camilletti Pit #2 proposal. According to Dr. David Cooper, the leading authority on wetlands science including the impact of water drawdown on wetland vegetation such as cottonwoods, the report's conclusions of wetland impacts is wrong. I do not believe its conclusions will stand up in a court of law under the close examination of an expert wifiess such as Dr. Cooper. Dr. Cooper states that "the report needs considerable work before it can be considered a complete analysis of the issues. " Dr. Cooper questions Gerdsoris entire thesis and we want the author to document why he believes his modeling is the correct one. Dr. Cooper lists several assumptions in the report that are not correct. We want an explanation from the author on his assumptions. The most telling statement is "The ideal mitigation proposed is to use subsurface irrigation techniques to raise the water table to the bottom of the root zone." Dr. Cooper says this is unsubstantiated. He goes on to ask whether Gerdson has submitted any examples of the use of sheet piles on floodplains actually being used with "subsurfacevrigation" to create a high water table. Dr. Cooper calls this "so speculative that it's unrealistic, "and based on his extensive experience he says, "I'm not convinced that this approach has any merit what so ever. We've done large scale experiments on the Green River in Browns Park to try to build up a water table under cottonwoods, and could not do it, even with very large pumps. " If an authority in this field has been unable to produce the results needed to successfully subsurface irrigate, then we have serious doubts that Mr. Camilletti will keep the