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Varra Companies, Inc. <br />Office of Special Projects <br />8120 Game Street Frederick, Colorado 80516 Telephone (970) 353-8310 Fax(970)353-4047 <br />1. Fill activities occupy lands north of the Cache La Poudre River, including the <br />establishment of significant berms on lands occupied by Greeley Urban <br />Renewal Authority, behind which lie active truck washout facilities and <br />basins, and an active mining operation. <br />2. Further east lie Anderson Salvage, which occupy a portion of the <br />floodway/floodplain with stockpiles of salvage metals and related operational <br />equipment and structures. <br />3. Still further to the east but within one mile of the location, lies Bliss Produce <br />active fill operations and warehouse facilities; and prior stream bed <br />extraction for fill material in the Cache La Poudre River. <br />4. West of the location, and adjacent to the Cache La Poudre River, old beat <br />processing stockpiles are being removed and the edge of banks of the River <br />modified by extraction. <br />5. Prior extraction lowering the original elevations for the creation of basins, or <br />topographic leveling of lands for a pivot irrigation system, as well as <br />placement of fill, has occurred by prior owners within the existing location of <br />the proposed permit boundary. Additionally, ditches, urban structures owned <br />by the City of Greeley such as a storm sewer and sanitary sewer, along with <br />unknown cuts and modifications in the embankments has occurred at this <br />location, along with diverse oil and gas facilities and lines, all to our <br />knowledge without prior protections for flooding. <br />The past uses on the proposed permit area, including the development of oil and <br />gas structures over a known mineral resource in contradiction with Title 34, <br />were likely placed without consideration for damage from potential flooding or <br />protections from the same. Either the threat of flooding was not considered or it <br />was not considered to be a significant threat. <br />This is not to say that flooding cannot or will not occur over this location, but we <br />believe the impacts of such an event will be localized and essentially beneficial <br />to the surrounding owners since the basins at this point in time, will provide <br />additional detention to waters, dissipating both velocities and lowering of peak <br />flows that would occur in the unaltered state of the location prior to extraction. <br />Further, operations will not encounter lands within 400 feet of the River until <br />many years hence when Tracts C and D are opened. <br />Varra Companies, Inc. correspondence of 23 February 2011 to the Colorado Office of Mined Land Reclamation 9 <br />(OMLR) in reply to OMLR correspondence of 4 October 2010 - Western Sugar Reclamation Land <br />Development Project - M-2010-049.