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~ ~~~ ~~~~~~~~~~~~~ ~~~ i geceived ' 26085 Highway 145 MAR 2 Dolores, CO 81323 ~ ~~~ March 17, 2001 ~ Dura ~E>'~I~ER O~ "'8gnc1M°eiebOyMe Division of Minerals and Geologp'7 F'j a/a 701 Camino de Rio ~'V 3~>'C F~~E ` ~~ & Genlogy, Room 125 LE; /~ _ OPy Durango, CO 81301 c~'d7-E` L, z v~/-~j0~ PO f~4,~.'r.; ~cip To the Division of Minerals and Geology and the Mine Reclamation Board: This letter is in reference to file number M-2001-001 -Four States Aggregates, LLC application to mine gravel at the Line Camp. In looking at their application 1 find many inadequacies. • According to the application p. 37 -status of vegetative cover- the site has up to 50% cover on the valley floor and is rated as being in poor condition. On p. 16 it says that reclamation will be deemed accomplished when a vegetation cover of 70% of the original vegetative cover is achieved. This means that at best there will be after reclamation a vegetative cover of 35%. • On p. 37 Robert Fuller (USDA,NRCS) is quoted as follows: "The site is heavily grazed and poorly managed especially from an irrigation standpoint. Bindweed, a perennial noxious weed is beginning to invade the field. Musk thistle and Western whorled milkweed are also present." 1 would contend that with the site being in this poor a state, a vegetative cover after reclamation of 35% is totally inadequate. • Fuller recommends (p.37) that the area be mowed for weed control the first year after reclamation. Musk thistle is a biennial and mowing for just one year will not control this invasive plant. Bindweed is also not controlled by mowing.With this degree of infestation, weed control is going to be an ongoing problem. • On p. 20 the reclamation plan describes 20 foot berms between the pit and the highway which will be topped with two foot high grass. How will the weeds be controlled on these stockpiles? • Although Fuller does suggest that the reclamation plan include the planting of native willow cuttings, buffaloberry, hardstem bullrush and bluejoint reedgrass azound the pond, there is nowhere any indication of how many of these plants will be planted. Will there be a few or many? • In light of the very degraded nature of this site, I question whether the amount of funds set aside for revegetation is adequate. • In the section of wildlife information beat, mountain lion, and river otters are not mentioned and all of these have been seen by neighbors. This is also a seasonal elk feeding ground. Elk are not mentioned. • The plan anticipates no effect on neighbors' wells. On what evidence is this based? If neighbors wells' or septic systems are affected, who will make good on them? • No study has been done either at the state or county level about the effect of gravel mining