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The applicant claims the pit will be a "dry" operation. Reported drilling of test holes by Lamben & Associates of Montrose, (we have as yet to be provided a copy oftheir report} suggested to the applicant there was between 20 and 60 feet of depth to Marcos Shale bedrock beneath the site. We believe these are reasonable estimates, as we observed gravel in west fork of Mexican Gulch to be 20-30 feet in thickness. Tn the existing Metcalf Pit, immediately east of the proposed operation ii is 50-b0 feet in depth. The entire site is underlain by Marcos Shale beneath the gravels, with varying elevations on the bedrock surface, i.e. erosion of the Mancos Shale surface was not planer, rather undulating and channelized by previous flows of the Uncompaghrt: River. The current hydrologic condi[ions are such that natural precipitation, non-consumed irrigation application (approxitately 50%) and leakage from ditches and canals recharge the mesa gravels. When this recharge encounters shale bedrock, satwates the gravels and moves laterally down gradiant (usually in a direction sinular to the surface topography) it . issues from springs at the base of the gravels along the arroyos which have eroded through the gravels into the shale bedrock. A prime example of large rechargelurigation return flow springs are those at Silver Springs Trout Farm, which flow at rates varying from 500 to 1000 gpm after mid-irrigation season. Testimony from local residents immediately east of the proposed pit indicate the Metcalf Pit, which now contains an excavated pond at it's base, fills with water during spring and summer months and water levels decline once imgation season terminates, until it is dry (last year) from late fall through winter. "this has been observed in numerous locations along the run of Spring Creek Mesa, including springs on the Bean Ranch. Phyreatophyte (water seeking) vegetation located in the arroyos southeast of the Pit, and more particularly in'the small arroyo located at the Metcalf Pit northward to Lasalle Road (and beyond on the Appleharu'Farm) are obvious testunony to the semi-perennial natwe of groundwater discharge along the Nlesa. Prior to the USBR "winter stock water program", which supplied domestic water taps for stock itt automatic waterers, ditch and canal leakage alone kept many springs running all year. , The Hillside Homestead (owned by Joyce and Harold Nation} is located in the NWI/4, NW ll4, Section 19, immediately adjacent to and east of 6200 Road, the eastern proposed boundary of the Pit. The Nation's have adjudicated water rights on.several sgiings and ponds under Division 4 District Water Court in Case #93CW242. Water Judge Robert Brown decreed the springs aztd ponds absolute on June 15, 1994. The decree specifies and spells out the operation of the springs and ponds as issuing surface water beginning in spring through summer and fall nwnths. The water is adjudicated for wildlife, livestock, irrigation and sub-irrigation of wetlands. Flows from the springs are individually adjudicated as high as 0.30 cfs (135 gpm}, with storage tights of up to 0.42 acre-feet in Otte pond alone. The elevation of the Nation Springs and ponds is approximately 50 feet below Spring Creek Mesa surface. The elevation of the water Ievei in the ittetcalf Pit Pond is similar. We have concluded that there can be no other source for these water rights but subsurface irrigation water recharge from irrigated lands to the west and southwest. In addition, the $ean Springy (observed} also receives recharge and flows from irrigated lands to the west. The excavation of this gravel deposit to shale