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FROM :SAGE HILL FRX N0. :970 785 6034 Rpr. 16 2002 12:29PM P2 <br />Mr. Anthony J. Waldron <br />lb Apri! 2002 <br />Page 2 <br />non-existem headgate to the wetland is not on my Farm, but rather on my noighbor's <br />farm. Therefore, this componenrt of the mitigation plan also cannot be implemented. <br />J, Mine Area 1 Conccm. In a January 22, 20021etter to me, W WE states: "The <br />wetland across from Mine Area 1 is several feet above 4,795 in elevation." This <br />difference in elevation between the wetland and Mine Area 1 is of great concern to me <br />because the groundwater under my farm is thought to flow generally in the northwest <br />direction (WWE states this in their November 2001 wetlands report on page 6.) My <br />concern is that the groundwater under the wetland will be continuously draining <br />into Lake 1, since the lake will be significantly lower than the wetland and to the <br />northwest of the wetland. <br />4. Crra~vity_Feed. W WE has proposed a gravity feed system over a pumping system <br />as a way to get water from Lake 3A to the wetland. T question if this reliance upon <br />gravity feed is based on the assumption that Ialce 3A will always have at or near the <br />maximum predicted water level. One concern I have is that water levels tend to vary, so <br />that agravity-fed system with no back-ap pump component might prove unreliable <br />during times of lowered water levels. <br />5. Width of Berms. Another concern I have is whether or not the 20' wide berms <br />proposed by WWE will actually separate the water between lakes. Considering that the <br />berms are made of highly permeable gravel, is this width enough to keep the water <br />between lakes separate? Because if it isn't, then all the lakes would actually function <br />as one big lake, which would change the lake leveling effect considerably and directly <br />impact the wetland. I have asked W WE to use basic and fundamental analysis to <br />demonstrate that a 20'-wide berm will be adequate, but this information has never been <br />provided. <br />6. TemnTrarv Verstig Permanent Variations in Groundwater Levels. In the <br />November 2001 WWE wetland report, in paragraph one on page 8, it states: "...the <br />wetland currently experiences relatively large fluctuations in groundwater levels and <br />hydrologic conditions, and the vegetation in the wetland is relatively tolerant to changes <br />in moisture conditions, Slight changes in groundwater levels, therefore, should not havo <br />a significant effect on the wetland." My concern is that the current fluctuations in the <br />wetland are temporary, i,e., the levels go up and down, up and down. Any changes <br />brought about by the Owens mining operation would be permanent. Permanent <br />changes, where the groundwater level does not bounce back up but is instead <br />permanently lowered, cannot be considered in the same light as temporary cl-anges. <br />For instance, a plant which might be able to with,~tand three weeks of drier conditions <br />before being inundated again, could not necessarily stand those same drier conditions on <br />a permanent basis. <br />7. Cum~lalive Effects of Groundwater Changes. In the November 2001 W WE <br />wetland report, in the third paragraph on page 8, it states: "...there could be small to <br />moderate changes in the groundwater levels beneath the wetland from a wet mining <br />