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6.4.7 Exhibit G - Water Information <br />2. In the Division's Adequacy Review - 02 letter dated January 2, 2011, the <br />Applicant was asked to provide a flood analysis and flood control plan. In lieu <br />of the requested information, the applicant has submitted a statement <br />explaining their position on the matter and has indicated that such information <br />will not be provided. The Division's authority to review information pertaining <br />to flood analysis stems from C.R.S. 34-32.5-116(4)(h) which states, <br />disturbances to the prevailing hydrologic balance of the affected land and of <br />the surrounding area and to the quality and quantity of water in surface and <br />groundwater systems, both during and after the mining operation and during <br />reclamation, shall be minimized. <br />The Urban Drainage and Flood Control District (UDFCD) Publication "Technical <br />Review Guidelines for Gravel Mining Activities within or Adjacent to 100- <br />year Floodplains" is utilized by the Division as a guidance document for mine <br />sites located within a 100-year plain. The UDFCD guidelines are designed for <br />gravel operations along the South Platte River and its tributaries and have <br />been used to review flood impacts of other sand and gravel operations <br />located on this particular reach of the Cache la Poudre River. The Division <br />utilizes the UDFCD document to provide initial guidance when reviewing <br />potential flood impacts. However, modifications to the guidelines are made on <br />a case-by-case basis to account for site specific conditions. <br />In order for the Division to evaluate the nature of the floodplain at the Western <br />Sugar Land Development Project site and determine if there are any site <br />specific reasons to relax the minimum berm width requirements, the <br />Applicant must submit a flood analysis and flood control plan. The Applicant's <br />proposal to rely on anecdotal evidence as a justification for ignoring the <br />potential flood hazards at the site is not acceptable. Please submit a flood <br />analysis and flood control plan for Division review. Failure to submit the <br />requested information will result in denial of the permit application. <br />The specifics of the flood analysis study and attending flood control plan are <br />being developed by C.G.R.S., and will be submitted to the OMLR under separate <br />cover. As such, the applicant requests that the permit be stipulated for approval <br />to wit: <br />Varra Companies, Inc. correspondence of 14 April 2011 to the Colorado Office of Mined Land Reclamation 4 <br />(OMLR) in reply to OMLR correspondence of 14 March 2011 - Western Sugar Reclamation Land <br />Development Project- M-2010-049.