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Page 3 of 6 <br />Division's authority to review information pertaining to flood analysis stems from <br />C.R.S. 34- 32.5- 116(4)(h) which states, disturbances to the prevailing hydrologic <br />balance of the affected land and of the surrounding area and to the quality and <br />quantity of water in surface and groundwater systems, both during and after the <br />mining operation and during 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 -year <br />Floodplains" is utilized by the Division as a guidance document for mine sites located <br />within a 100 -year plain. The UDFCD guidelines are designed for gravel operations <br />along the South Platte River and its tributaries and have been used to review flood <br />impacts of other sand and gravel operations located on this particular reach of the <br />Cache la Poudre River. The Division utilizes the UDFCD document to provide initial <br />guidance when reviewing potential flood impacts. However, modifications to the <br />guidelines are made on 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 specific <br />reasons to relax the minimum berm width requirements, the Applicant must submit a <br />flood analysis and flood control plan. The Applicant's proposal to rely on anecdotal <br />evidence as a justification for ignoring the potential flood hazards at the site is not <br />acceptable. Please submit a flood analysis and flood control plan for Division review. <br />Failure to submit the requested information will result in denial of the permit <br />application. <br />As discuss during the adequacy review for the permit application, the Colorado Water <br />Conservation Board (CWCB) is developing a guidance document specifically focused on the <br />gravel mine operations within floodplains. The guidelines are expected to provide a set of <br />criteria for mining operations located within the floodway and floodplain. <br />The Division suggests the Operator withdrawal TR -01 and resubmits the required technical <br />revision addressing a flood analysis and flood control plan for the Western Sugar <br />Reclamation Land Development Project based on the CWCB guidelines following the release <br />of the guidelines. <br />Weld County — Flood Hazard Development Permit Application letter — November 21, 2011 <br />2. On Page 2 and 3, the application letter states the proposed sand and gravel operations will <br />include a conveyor. A conveyor was not discussed nor approved in the Mining Plan for the <br />site. Please explain this discrepancy and commit to submitting the appropriate revision <br />type to include a conveyor in the Mining Plan prior to construction. <br />3 <br />