2008-03-17_PERMIT FILE - M2008010

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~~ M - 2 008- ono kQ~ Marcos Conservation District P.O. Box 308 Marcos, CO 81328 March 14, 2008 Colorado Mined Land Reclamation Board ~~~~~~~® Division of Reclamation, Mining, and Safety 1313 Sherman Street, Room 215 MAR 17 2008 Denver, Colorado 80203 ~ Division or ~eciamation, Mining and Safety Regarding: McStone Aggregate LLC application for a Regular (112) reclamation permit to conduct the extraction of construction materials operations in Montezuma County. Dear Board Members: The Mancos Conservation District Board of Supervisors has completed an initial review of the February application for Mud Creek Pit and have the following comments. First, there is a larger perspective on construction materials extraction in the Mancos Conservation District than is apparent from the McStone application. There is the Noland Cedar Point Pit that has been operating since the mid 1990s, the Mud Creek Pit (this application), and a new pit to be established on the Simmons property for which negotiations are underway. These three operations are on adjacent parcels of land and when completed will affect contiguous areas on the western escarpment of Mud Creek. We request that the reclamation plans of these pits be considered in consort so that the post mining landscape has the proper drainage and land form to support agriculture or other uses. We also encourage as much sharing of haul roads, access points to US Highway 160, and processing machinery as is possible to reduce both the long term modification of the landscape and the short term aesthetic, noise, dust, and traffic disruption of the community. The Mancos Conservation District is willing to work with these entities to achieve this end, if your board thinks that would be helpful. The Mancos Valley is a topographically enclosed area with mountains trapping air moved across the Valley by prevailing winds. The Valley also has temperature inversions almost daily and in all seasons that trap dust and aerial effluents neaz the ground causing more problems than in areas where effluend dissipation occurs more readily. Therefore, it is crucial that rules be established and stringently enforced that will eliminate particulate and aerosol discharge that might move beyond the described property boundaries of the Mud Creek Pit. Where dischazges cannot be completely controlled, we suggest placing those activities in nearby areas outside the Mancos River Watershed where dissipation and dilution is more rapid. The water rights associated with the McStone property (0.295 cfs of Priority #8 surface flow water from the Mancos River and 85 acre feet of stored water from Jackson Gulch Reservoir) are insufficient to restore irrigated pasture/cropland use to more than about 20-30 acres in our climate. The remainder of