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than under current conditions, thereby requiring additional irrigation; i.e, "sub- <br />irrigation" as a common practice will be much more difficult. <br />7) Until such time as alt irrigation is terminated in the area surrounding the pit, and <br />irrigation delivery systems Gear the pit are piped, lined or otherwise sealed (ot are <br />abandoned), the pit wr7] continue to act as a groundwater sump, If those <br />conditions were met, the pit would stiIE act as a sink for natural precipitation and <br />recharge to the mesa gravels. <br />S) The proposed reclamation plaa is inadequate in many areas, particularly is that <br />the proposal is to place "waste material" on the bottom and slopes of the <br />excavation, wveriag with six inches of topsoil, and returning the acreage to either <br />pasture or cropL9nd. Croplaad in Montrose County requires irrigation, and no <br />methods or application techniques have been proposed. Natural groundwater and <br />irrigation flow recharge dursng 6-9 months of the year will negatively impact <br />either pastureland or cropland, and irrigation water application through flood <br />irrigation, row crop application or sprinklers would Ue ineffective much of the <br />Y~'• <br />9) The Proponent states that existing itrigation water rights would be used for <br />supplying water ro the pit for dust suppression and processing. It is our <br />understanding that, while project water may be used on the property for industrial <br />or commercial purposes initially, when the Uncompaghre River system is "on <br />caU" these waters may be used only for adjudicated purposes, i.e, irrigation and <br />IivesWCk use only. <br />lt))No groundwater testing, monitoring or test hole drilling data (Lambert) has been <br />provided. without this data, the proposed "dry operation" plan has no efficacy. <br />Until such data is acquired and reviewed, quantitative impacts cannot bo <br />determined. <br />ll)The proposed industrial ogetatioas (heavy equipment, trucks, asphalt and <br />chemical storage) pose a serious risk to groundwater quality. Direct <br />contamination to the groundwater by spilled, leaked or applied chemicals will <br />diminish thest waters and, potentially, contatnisrate surihce waters of the <br />Uncompag)rre River. No mitigation plans are presertted for this possibility. <br />In summary, we believe the application is defecient in it's lack of specificity on <br />reclamation plan, as well as void of any documentation of groundwater Levels, monitoring <br />and flow, impacts to neighboring waters or water right changes sad apgropriations. <br />Overall impacts to the hydrologic conditions on Spring Creek Mesa have so far been <br />ignored. <br />Should your group wish to continue investigating this application, end require additional <br />input, please feel free to contact our office at your convenience. <br />~spectfullY, <br />II1t1L. D , ,P.G~`- <br />Cc: Andy Mueller/Sue Mcimosh <br />Z <br />