2009-06-30_PERMIT FILE - M2009018 ‎(8)‎

• Permit No: M2009018
• IBM Index Class Name: PERMIT FILE
• Doc Date: 6/30/2009
• Doc Name: Reply to Preliminary Adequacy Review
• From: Varra Companies, Inc.
• To: DRMS
• Email Name: MAC
• Media Type: D
• Archive: No

Varra Companies, Inc.
Office of Special Projects
8120 GaM Street Frederick. Colorado 80516 Telephone [phone] Fax[phone]
image showing the irrigated pasture grass of the lower flood plain and the upland area comprised
of dryland pasture grass over Tract C.
While such a description has satisfied the Office in previous submittals, we have revised Exhibit
UJ: Soils & Vegetation Map to comply with your request, and in a manner consistent with the
previously submitted information. Please be aware, vegetation cover over agricultural lands can
vary over time to meet landowner objectives, and the Range Site Descriptions were provided as a
superior means to understand the potential of the site when benchmarked to native conditions.
5. The Application states in Exhibit D that Tracts A and B are within the upper terrace of
the flood plain of St. Vrain Creek. Please depict the FEMA designated flood plain on Exhibit C-
2: Extraction Map.
As stated on page 2 of Exhibit D - Mining Plan, a complete reading of the paragraph continues:
...While found within the upper terrace of the flood plain of St.
Vrain Creek, the FEMA designated flood plain does not reach the site
location since a rail road bed to the northwest intercepts and prevents
flood waters of St. Vrain Creek from reaching the location.'
Since the position of the project location to the railroad bed and St. Vrain Creek are visible in the
included aerial image on Exhibit C-2: Extraction Map, it seemed sufficient at the time to
distinguish in the text the limits of the active FEMA flood plain without contributing additional
symbolism and graphic overlays on the map; perhaps illuminating that relationship and
obfuscating others by including too many graphics over the attending image.
So to be clear; while Tracts A and B lie within the historic flood plain, a modification of the
historic flood plain by the introduction of rail and a corresponding railroad bed earlier in the
Twentieth Century changed the physical extent of the flood plain as it behave today. This
change was later reflected on FEMA drawn maps.
It appears that the Office is seeking assurances that the position of the current active flood plain
if verified respective of its relation to the historic flood plain wherein lie Tracts A and B. To this
end, and to assure the existing clarity of Exhibit C-2: Extraction Map for other features, we have
instead provided a copy of the actual FEMA map publication showing the respective location of
the project location (refer to quarter section description) to better address the Office's concerns.
We hope this slight modification of your request will satisfy the concerns of the Office.
6. Rule 6.4.3(g) requires the applicant to identify the owners of any significant, valuable,
and permanent man-made structures within two hundred feet of the affected land. Please provide
the owner's name with any associated structures on the Extraction Map.
We believe part of the concern is over working Exhibit C-2: Extraction Map to display diverse
and detailed information over a large area. The problem appears to be one of scale. Because of
Varra Companies, Inc. correspondence of 30 June 2009 to the Colorado Office of Mined Land Reclamation 3
(Office) in reply to Office correspondence of 12 May 2009 - Heintzelman Project - M2009-018.