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.~ the quarry application concealed the magnitude of impacts and requires extensive work to revise the following: .; Southwestern claims that seeps from the St. Vrain Canal have created the wet areas downgradient from the canal. The facts aze to the contrary. First, extensive hydrologic ~ ' ~ studies at Syntex Chemical's landfill, located upgradient of the Canal and abutting the quarry site, characterized the hydrology of Dowe Flats. Southwestern ignored Syntex's h drolo is data source that confirnts roundwater from the under) to Dakota sandstone ~`: Y g 8 Y~ g has positive pressure (upward movement) that supplies springs. Second, pre-St. Vrain Cana! topographic maps show the existence of springs in Dowe Flats. Discharges from the Dakota sandstone is the primary water source of the upper wetlands. Third, the relic stream channels crossing Dowe Flats, northwest to southeast and north to south, further support the argument that construction of the St. Vrain Canal actually decreased the amount of water available to support wetlands on the project site. • Southwestern claims that Boulder Highway 47 blocks flow of water on site creating wet zones that otherwise would not exist. The facts are that most of those "wet" areas appear to be disturbed wetlands located in the relic stream channels on site. The amount of wetlands created on site appears to be significantly less than wetlands destroyed on site from blockage and capture of the natural drainage by the St. Vrain Canal. Southwestern claims that wetlands in the project area having non-wetland plant species are not wetlands and require no permit to fill. The assumption is based on the lack of a preponderance of wetland plant species due to cultivation and severe impacts from livestock grazing. [dispute Southwestern's claim that wetlands currently in agricultural use may be converted by draining for the quarry use without a permit (See letter dated 28 August 1990 from Aquatic and Wetland Consultants in wetland appendix). Court cases have upheld the policy that agricultural exemptions are only allowed for current use without a permit; the quarry project does not qualify as current use. EPA's -Region 8 Wetlands Section can explain the limitations for agricultural exemptions based on court cases. The wetlands definition quoted, from the Federal Register (1977), in the "Appendix - Dowe Flats Project Wetlands" method's section is correct. "Those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do sunoort. a prevalence of vegetation typically adapted for life in saturated soil conditions." Emphasis added since severe damage to normal plant communities in wetlands from livestock grazing and cultivation has created abnormal conditions at Dowe Flats. Southwestern conveniently used their own vested interest definition. On page 2 of the wetlands appendix, Southwestern tries to give authority to their definition by emphasizing that only when "ALL" wetland indicators were present did they consider the area to be wetland. Excuse me but grazing and farming in wetlands at Dowe Flats are not normal circumstances and "ALL" wetland indicators will not occur as a result of the environmental disturbances. The baseline data provided by the applicant is too inaccurate for assessing environmental impacts the project.