2011-02-24_PERMIT FILE - M2010049 (2)

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Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone (970) 353-8310 Fax(970)353-4047 the others. If this operation is to be responsible for securing the protection of the others, the costs and burdens of such protection should be compensated for accordingly. The unfortunate use and dumping of concrete rubble along the streamside banks of active rivers in the mistaken understanding that it protects and stabilizes riparian property from the course altering work of flood waters should be discouraged. Often, when streamside banks fail it's because the floodwaters cut the stream bed and in the process undermined the stability of the adjacent banks; or streamside elevations were low enough to aid entry and are a natural part of the braided stream as typified by meanders and older meander scars reflecting the natural tendency of such rivers to change course. The concrete riprap simply acts to thwart a more stable, diverse and beneficial presence of native vegetation that would better function to improve the streamside habitat. Speaking generally, we find the exaggerated use of engineered structures, reflects a tendency to utilize engineering to circumvent controversy from a misinformed public or other public authority, or as a substitute for personal judgment and responsibility. Without enumerating the source or their fears, often it fails to hold up in the face of sound environmental or fiscal reason. Correspondingly, we find ourselves adverse to believe the OMLR would indulge in such expediencies. While we respect the burdens and fears that the staff of OMLR must suffer for its diverse responsibilities, we cannot in any reasoned appraisal of factors in play at this location and surrounding lands, find merit in the application of UDFCD guidelines in this instance. The attending burdens such measures would pose upon the location do not have an apparent correlated enumerable or coequal benefit. Upon subsequent reflection, with what we trust has been a clearer presentation on our part of the causal elements at play, we are confident the OMLR will substantially concur with our perspectives. If a stretch of a natural river is to be engineered so as not to meander, then a plan should already be in place for the entire stream segment, from which any modifications must comply with the engineered aspects of the segment. This condition does not exist along this segment of the Cache La Poudre River beyond the defined determinations of a floodplain/floodway, which planned operations could only serve to benefit. In all other aspects, the guidelines proposed will serve to place an unusual burden on the applicant and force the development of civil structures beyond that of other landowners within the stream segment; in effect for the protection of civil structures that were placed Varra Companies, Inc. correspondence of 23 February 2011 to the Colorado Office of Mined Land Reclamation 11 (OMLR) in reply to OMLR correspondence of 4 October 2010 - Western Sugar Reclamation Land Development Project- M-2010-049.