HomeMy WebLinkAbout1.05 Appendix E - Impacts Analysis-Wetlands-Dewatering
IHC SCOTT RIFLE PIT #1
IMPACT ANALYSIS REPORT
RIFLE PIT #1
IHC SCOTT (SCOTT CONTRACTING INC.)
MARCH 2021
Prepared by
118 West Sixth Street, Suite 200
Glenwood Springs, CO 81601
970.945.1004
970.945.5948 fax
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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TABLE OF CONTENTS
1.0 Rifle Pit #1 Impact Analysis 1
1.1 Adjacent Land Use 1
1.2 Site Features 2
1.3 Soil Characteristics 8
1.4 Geology and Hazard 8
1.5 Groundwater and Aquifer Recharge Areas 8
1.6 Environmental Impacts 9
Long-term and Short-term Effects on Flora and Fauna 9
Determination of the Effect on Designated Environmental Resources, including Critical
Wildlife Habitat 9
Wildlife and Domestic Animals 10
Potential Radiation Hazard 10
1.7 Nuisance 10
1.8 Hours of Operation 11
LIST OF FIGURES
Figure 1. Properties within 1,500 feet of Rifle Pit #1 3
Figure 2. Topography and Existing Conditions of the Rifle Pit #1 Property 4
Figure 3. Waterbodies near the Rifle Pit #1 Property 5
Figure 4. Soils at the Rifle Pit #1 Property 6
Figure 5. Proposed Condition (Reclaimed) of Rifle Pit #1 Property 7
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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1.0 Rifle Pit #1 Impact Analysis
This report documents the existing conditions and the potential changes created by the Rifle
Pit #1 project and describes how IHC Scott (Scott) [formerly Scott Contracting, Inc. (SCI)]
will ensure that impacts will be mitigated, and standards will be satisfied. The following
sections address the information required in the Land Use Development Code (LUDC)
Section 4-203.G.
1.1 Adjacent Land Use
Per Garfield County submittal requirements, a list of landowners and mineral rights owners
within 200-feet of the proposed project parcel is included with this submittal. Adjacent
landowner addresses were obtained from the Garfield County Assessor’s web-based
database.
There are four adjoining properties with corresponding surface landowners:
· North – Colorado River Ranch, LLC
· West – Rex Robinson Ranch, LLC; Swanson Colorado Trust; Ilgen, Carrol Jeanne;
Rosa, Linda Jane; Robinson, James Dean
· South – Colorado Department of Transportation (CDOT)
· East – Shidelerosa LLP
This information was obtained from the Garfield County Colorado Land Explorer (Garfield
County, March 2021).
North Side: The parcel adjacent to the north is owned by Colorado River Ranch, LLC and is
currently zoned Rural. There aren’t any compatibility issues with the proposed project since
the current use is agricultural.
West Side: The Rex Robinson Ranch, LLC, currently owns the property to the west. This
property is zoned Rural. There is currently an oil & gas pad on this property which isn’t
currently being used. The current use of this property is compatible to the proposed mine
project..
South Side: The property to the south is currently owned by CDOT (I-70 N Frontage Road,
also referred to as County Road 346) and is parallel to the property.
East Side: The property to the east is owned by Shidelerosa LLP and is zoned Rural. This
property is currently used for agricultural purposes and there is one residential driveway
approximately 0.45-mile from the proposed mine property.
All landowners have been notified of the proposed development. The proposed use is
consistent with the predominant existing uses in the surrounding area.
Figure 1 depicts the existing use of the adjacent properties within a 1,500-foot radius of the
Rifle Pit #1 property.
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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1.2 Site Features
Figures 2 through 4 depict the existing conditions of the waterbodies, topography, and
vegetation cover of the property.
Figure 5 depicts the proposed condition of the property.
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021 3 Figure 1. Properties within 1,500 feet of Rifle Pit #1
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021 4 Figure 2. Topography and Existing Conditions of the Rifle Pit #1 Property
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021 5 Figure 3. Waterbodies near the Rifle Pit #1 Property
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021 6 Figure 4. Soils at the Rifle Pit #1 Property
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021 7 Figure 5. Proposed Condition (Reclaimed) of Rifle Pit #1 Property
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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1.3 Soil Characteristics
According to the USDA NRCS Web Soil Survey, most of the soil map units in the permit
area are ranked as fair gravel sources and one soil unit (Olney loam) is ranged a poor. All
the soils except the Kim loam is rated as fair condition for sand sources. Approximately 50%
of the permit area has soil units that are rated as fair to good for reclamation material.
Where/when applicable, the top 4 - 6 inches of topsoil will be salvaged and stored for later
reclamation uses. The soils within the subject parcel are mapped by the NRCS as soil units:
· Halaquepts, nearly level
· Kim loam, 3 to 6% slopes
· Olney loam, 1 to 3% slopes
· Wann sandy loam, 1 to 3% slopes
Note this property is being considered for gravel extraction as a result of the presence of
these soils.
The post-developed condition of the property will result in an 18.4-acre pond while the
surrounding land around the pond will be restored to its natural condition. Scott plans to
reclaim the property as each mining stage commences. Areas disturbed during development
shall be restored with natural-appearing landforms that blend with the adjacent undisturbed
topography within 90 days of completion. Details regarding reclamation processes and
revegetation can be found in Section 2.12.7 of the Land Use Permit. See Figure 5 for the
post-mining site conditions.
1.4 Geology and Hazard
No natural geologic nor manmade hazards exist on the property that would influence the
proposed use of the site.
1.5 Groundwater and Aquifer Recharge Areas
The Colorado River borders the property to the north. A berm will be constructed to minimize
the influence of the Colorado River on the proposed land use and operations. The height of
the berm will be 5 feet and was determined by conducting floodplain modeling. See Land
Use Permit for additional information on the floodplain modeling and floodplain analysis.
The principal aquifer properties at the site are:
· Saturated thickness (b) – the thickness of the saturated porous medium measured
as the difference between the static water level and the base of the aquifer,
measured in feet. Average saturated thickness of 18 feet at the site.
· Hydraulic conductivity (K) – a measure of the capacity of a porous medium to
transmit a volume of water through a unit cross-sectional area, typically expressed in
units of feet per day. The aquifer at the site is assumed to have a uniform hydraulic
conductivity of 1,000 feet per day.
· Storage coefficient or specific yield (Sy) – the volume of water released from a unit
volume of saturated aquifer per unit decline in head, expressed as a fraction. The
aquifer at the site is assumed to have a uniform value of 0.2 for specific yield.
· Transmissivity (T) – a measure of the capacity of a porous medium to transmit a
volume of water through the entire saturated thickness, expressed in units of feet2
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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per day. Transmissivity is obtained by multiplying the hydraulic conductivity by the
saturated thickness (T = K x b). Transmissivity is approximately 18,000 feet2 per day.
The proximity of the property to the Colorado River, the proposed dewatering activities and
excavation of the site for mining does not allow for a subsurface wastewater facility. The A
vault and haul waste system will be sited away from the perimeter of the property to
eliminate the potential for a discharge to the ground and surface waters. Trash receptacles
will also be sited away from the perimeter of the property to minimize the influence of trash
from being discharged from the site.
The Land Use Permit document includes a dewatering modeling analysis and Wetlands
report, that outlines the existing and proposed vegetation conditions of the site.
1.6 Environmental Impacts
The determination of the existing environmental conditions on the parcel to be developed
and the effects of development on those conditions specific to flora and fauna, wildlife and
domestic animals, and radiation hazards are described in the following sections.
Long-term and Short-term Effects on Flora and Fauna
Vegetation in the subject parcel is dominated by partially irrigated pasture lands, which are
subjected to an inconsistent and uneven application of irrigation water via flood irrigation
and subsurface seepage. The mixture of mesic and hydric soil conditions supports a mosaic
of upland pasture areas and wet emergent meadows, with the water table so elevated in
some portions that the wet meadows contain areas of open surface water. Some small
areas contain sparse riparian woodland, dominated by non-native Russian olive (Elaeagnus
angustifolia) with a sparse overstory of cottonwood (Populus deltoides). The wetlands will be
avoided during Stage 1 and Stage 2 mining activities.
The project occurs in mesic wet meadows and pastures. Most of the affected area has seen
extensive development activities associated with grazing management, including trenching,
disking, irrigation, and fence construction, and the habitats are already significantly
disturbed. Animal species that are tolerant of, or habituate to, human activity persist in the
area, and use the property on an intermittent and seasonal basis. The level of human
disturbance is sufficiently great to preclude permanent occupancy of the parcel by wildlife
species of concern.
Determination of the Effect on Designated Environmental Resources, including
Critical Wildlife Habitat
Mining will remove vegetation in phases allowing incidental use of the site by wildlife, if
needed. Wildlife will likely avoid the parcel entirely once mining development commences,
and the existing level of casual use will be displaced to adjacent unimpacted habitats along
the southern bank of the Colorado River. It is expected that the itinerant species will
continue to utilize surrounding habitats given the small area of the mine. However, the
existing mosaic of meadows and riparian woodland will not be recovered, and the property
will support a much less complex environment dominated by agricultural cultivars. This could
continue to provide winter grazing habitat for elk and mule deer, although the habitat quality
would be low due to a lack of woody cover vegetation. Wild Turkey would likely abandon the
parcel. Bald eagle foraging is concentrated along the Colorado River, and would be
minimally impacted by the proposed development. Most small mammal and passerine bird
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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species will be able to resume use of the area once reclamation is complete; the longest-
term potential habitat detractor will be persistence by noxious weeds.
The area is seasonally used by the following species (based on CPW & COGCC RSO/SWH
habitat data):
· Bald Eagle (Winter Forage, Winter Range)
· Elk (Severe Winter Range, Overall Range)
· Mule Deer (Resident Population Area, Severe Winter Range, Winter Concentration
Area, Winter Range, Overall Range)
· Wild Turkey (Winter Concentration Area, Winter Range, Overall Range)
Wildlife and Domestic Animals
There are no significant wildlife resources on potentially affected lands. The site supports
seasonal, low-level big game use, and typical use patterns of mesic shrublands and
pasturelands.
The impact to area wildlife should be minimal as a result of this project. A 5-foot tall berm will
be constructed around the perimeter of the site therefore some wildlife may experience a
slight change in traveled corridors to maneuver around the mine area. See Section 2.10.2 of
the Land Use Application for more detailed discussions regarding Wildlife Habitat Areas.
Potential Radiation Hazard
The Colorado Department of Public Health and Environment (CDPHE) has posted a
statewide radon potential map on their website based on data collected by the EPA and the
U.S. Geological Survey. Garfield County and most of Colorado has been mapped as being
within Zone 1 – High Radon Potential or having a high probability that indoor radon
concentrations will exceed the EPA action level of 4 picocuries per liter (pCi/L).
Radon is not expected to be a significant problem at the proposed site since the mine will
not include any permanent structures, personnel will not be onsite for extended periods, and
the site will not be developed with structures containing basements or substructures with
radon can accumulate.
1.7 Nuisance
Scott understands that all gravel operations proposed to mine areas greater than 30 acres
shall be designed in multiple phases in order to minimize the visual impact of the gravel pit
primarily by logical “sequencing” and “overall layout” of the pit’s design. Section 1.1.7 and
Figures 3 and 4 describe and depict the mining stages for Phase 3 of this project. This
approach integrates the use of berms along the perimeter of the site. These berms will be
placed inside of a 25-foot set back area from the property line. These berms will be roughly
5-feet in height and 23-feet wide at the bottom built at 2H:1V slope. The berm will support
noise mitigation during operations and provide a screen to buffer visual impacts. The berm
will be constructed prior to commencing any mining activity by phase. Site preparation
activity such as removal of overburden shall be allowed prior to the construction of the visual
screening if material will be used for the creation of the necessary screening.
IHC Scott – Rifle Gravel Pit #1 Impact Analysis Report March 2021
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The location of the mining equipment in the bottom of the pit will also support mitigation of
the mining noise and dust. All stockpiling of material at this point also be done at this level.
1.8 Hours of Operation
The Rifle Gravel Pit #1 will operate from 7 a.m. to 7 p.m. Monday through Friday, and
weekends, as needed. Scott will limit winter operations between the hours of 7 a.m. and 5
p.m. Approximately 3 to 5 employees will be on site during the mining operations. No
nighttime activities are anticipated. Occasional equipment repair, or maintenance may be
conducted at night, but lighting will be kept to a minimum and directed inward; the site will
not have ambient lighting.
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Figures
Figure 1. NWI Wetlands Map.
Figure 2. Initial Wetlands Mapping by SGM (July 17, 2019).
www.sgm-inc.com
EXHIBIT F
June 26, 2020
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Wetlands Delineation Finding
Fill and dredging within Waters of the U.S. and tributary wetlands are regulated by the US Army Corps of
Engineers (USACE) under Section 404 of the Clean Water Act (CWA). The National Wetlands Inventory
(NWI) provides the user with information to conduct an initial desktop assessment and generate maps of
the potential extent of jurisdictional waters for any area of interest. As a national-level dataset, the NWI is
not and cannot be entirely accurate at a local level and should always be evaluated against a field-based
study of conditions on the site. The NWI for the Rifle Pit #1 property (Property) indicates that the area
consists of a mosaic of upland areas interspersed with wetland zones dominated by herbaceous emergent
vegetation (Figure 1). A site visit and delineation performed by SGM on July 17, 2019 generally confirmed
that this parcel contains large areas of wetlands dominated by cattail and bulrush emergent communities,
although these areas are not as extensive as suggested by the NWI (Figure 2). The wetland areas are
concentrated on the west end of the property and are well-developed and relatively high-quality from a
biological and functional perspective. The east end is mesic pasture meadow rather than jurisdictional
wetlands, and development of the gravel resources in this area could be accomplished without Section 404
permits or impacts to Waterbodies protected by the Garfield County Land Use Development Code
(LUDC).The Last Chance Ditch enters the Property from the east; this is an artificially-excavated, gated
and controlled irrigation ditch and as such is explicitly excluded from consideration as a protected
Waterbody in the LUDC. The Last Chance Ditch and its laterals discharge tailwaters onto the surface of the
Property, at numerous locations.
Parcel Geology
Boring logs (HP Geotech, 2008) and direct observation indicate that the entire Property is underlain by a
consistent subsurface column consisting of (a) silty clay loam from the surface to a depth of 3 feet, (b) an
impermeable clay aquitard layer at a depth of approximately 3 feet, (c) dry gravel to a depth of approximately
7 feet, and (d) saturated gravels in direct contact with the water table starting at a depth of 7 feet (see Land
Use Permit Application, May 2020).
The site visit and supplemental subsurface documentation suggests that the wetlands are supported
entirely by irrigation tailwater discharge onto the Property, which pools on the shallow clay aquitards and
forms a perched zone of saturation above dry gravel. There is no indication of natural surface hydrology on
the Property: surface water reaches the property exclusively via artificially-excavated channels off the Last
Chance Ditch, including the large lateral/tailwater ditch that bisects the property from east to west, and
several smaller ditches that discharge underneath the interstate and onto the southern boundary of the
property (Figure 3). The available drilling data consistently show that the water table is approximately 7
feet below the surface, and that 3 or 4 feet of dry gravel intervene between the zone of surface saturation
and groundwater.
Based on this understanding of the hydrology, if the tailwater discharge onto the property are stopped (by
closing headgates, re-routing and/or piping the ditches, or other similar methods), the primary water source
for the wetlands will be removed. Groundwater modeling also suggests that pit dewatering activities in
adjacent upland areas (east) will significantly and rapidly depress groundwater levels throughout the
Property, further isolating the wetlands from groundwater hydrology (See attached Letter Report, Hahn
Water Resources, LLC, August 2, 2019 and July 8, 2020).
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The combination of pit dewatering adjacent to the wetlands, and removal of irrigation-derived water
discharges onto the property, are expected to remove the hydrology supporting the wetlands throughout
the Parcel. It is expected that the areas currently mapped as wetlands per the USACE and LUDC criteria
(Figure 2) will cease to display wetland hydrology and/or hydrophytic vegetation within two growing
seasons and will no longer meet the criteria as wetlands under USACE jurisdiction or as Waterbodies under
LUDC definitions.
Army Corps Section 404 Permitting Considerations
The USACE regulates the discharge or dredging of sediment into wetlands, including activities such as the
commercial development of gravel resources, however wetlands supported entirely by irrigation water
(a.k.a. agriculturally induced wetlands) are not regulated.
The eastern portion of the Parcel does not contain jurisdictional waters or wetlands, and development can
proceed in this area without further Section 404 permitting considerations. SGM’s site investigation
completed on July 17, 2019 will be formalized in a wetland delineation report to provide confirmation of
regulatory compliance, once development of the gravel operation is approved and the precise extent and
nature of the initial development activities are determined. In addition, groundwater pumping is not
regulated by the USACE, nor are indirect impacts to wetlands due to an adjacent pit dewatering operation
(USACE, T. Morse, pers. comm.). Therefore, although initial gravel pit dewatering in the eastern portion of
the property will depresses groundwater in adjacent wetlands and contribute to a loss of wetland conditions,
that activity is not regulated and does not require a permit under Section 404. Dewatering permits from the
Colorado Department of Public Health and Environment (CDPHE) – Water Quality Control Division (WQCD)
and the Division of Water Resources (DWR) are required for dewatering operations.
The NWI mapping, which shows much of the western portion of the Parcel as wetlands, means that prior
to developing those areas, the burden of proof is on Scott Contracting to prove to the USACE that the
wetlands are either (a) supported entirely by irrigation water and therefore non-jurisdictional, or (b) no longer
meeting the regulatory definition of wetlands. In general, no more than 0.5 acres of direct wetland impact
can be permitted without going through the extensive USACE Individual Permit process, therefore seeking
a permit for impact to the wetlands is incompatible with effective development on the Parcel. However,
documenting that the Parcel no longer contains wetland characteristics will allow full development on the
site.
Based on the underlying hydrology and geology described above, Scott Contracting believes that by
removing irrigation tailwater discharge from the Property and rerouting the Last Chance Ditch and laterals,
will remove the sole water source for the wetlands and result in the loss of wetland characteristics. Scott
will monitor and document the change in wetland conditions and will seek formal confirmation of the findings
from the USACE via an Approved Jurisdictional Determination. Once the USACE has formally recognized
that the removal of irrigation water has resulted in the loss of wetland criteria, indicating that the wetlands
are agriculturally induced, Scott Contracting will proceed to develop the remaining portion of the Property.
Garfield County Wetland Impact Considerations
Garfield County’s definition of “wetland” relies on the same fundamental criteria as the USACE: the
presence of continuous or reoccurring saturation/inundation, the development of chemical signatures in the
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soil that indicate anaerobic conditions typical of long-term saturation (i.e. “hydric soils”), and the dominance
of plant species that depend on saturated soils (i.e. “hydrophytic vegetation”). Therefore, the wetland
delineation performed for the Property (Figure 2) accurately describes the extent of wetlands/Waterbodies
under the LUDC, as well as under the CWA. However, unlike the CWA the LUDC does not distinguish
between wetlands supported by natural hydrology and those that are agriculturally-induced, and in fact the
LUDC explicitly requires the disclosure of impacts to wetlands, regardless of “whether or not they are
jurisdictional as defined by the Corps of Engineers [USACE]” (Article 14-401.T). Based on this reading of
the LUDC, Figure 2 should be taken to indicate the extent of proposed impacts to wetlands, as required by
Article 4-203.G. The proposed gravel pit operation on the Property would result in development within
wetland areas and within the 35-foot buffer zone around Waterbodies, and therefore a waiver for this
development is requested.
The waiver request is based on the following factors:
· Hydrologic studies, drilling logs, and site observations indicate that the wetlands on the site are
supported by irrigation water rather than natural hydrology.
· The proposed gravel operation is not logistically feasible without re-routing the current tailwater
ditches and initiating groundwater pumping to dewater the pit, which would remove the irrigation
water supporting the wetlands.
· The development of the initial phase of the gravel operation, confined to the eastern portion of
the Property outside of wetland areas, is expected to result in the loss of wetlands from the
remainder of the Property.
· The proposed gravel operation is financially feasible only if most of the Property is developed,
including the areas of agriculturally induced wetlands.
· The reclamation of the site would produce habitat value that would replace the lost values to
some extent, since the gravel pond would support a wetland fringe on its periphery. These
wetlands would be supported by natural groundwater rather than irrigation tailwaters, and
therefore would be protected under the CWA.
Recommended Monitoring & Development
Based upon the wetland and groundwater modeling evaluations performed to date, Scott Contracting will
proceed with the two-pronged approach to remove the hydrology which supports wetlands on the Parcel,
while remaining in compliance with the CWA and the LUDC:
1. Remove all irrigation water discharge onto the property by rerouting the Last Chance Ditch to
the northern boundary of the Property (See Drawings attached to NTC Letter)
2. Maintain dewatering in the initial pit development, to be in the upland eastern portion of the
Property, which will depress groundwater throughout the Property.
SGM will monitoring wetland conditions on a quarterly basis, using the standard USACE wetland delineation
protocols to track the response of the hydrology and vegetation to the altered hydrology. Quarterly reports
will contain conditions assessments and maps of the evolving extent of wetland areas, and the results will
be shared with the USACE on a regular basis. Physical boundary indicators (such as earthen berms or silt
fence) will be maintained to prevent any inadvertent transgression into areas that retain wetland
characteristics during the initial phases of development. The quarterly reports will allow Scott Contracting
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to document that all ongoing activities follow Section 404 regulations and would also document the point at
which wetlands disappear from some or all the Property.
At the point when monitoring indicates an unambiguous loss of wetland characteristics from the Property,
Scott Contracting will submit the revised delineation results to the USACE and request an Approved
Jurisdictional Determination (AJD), which would formally recognize that the NWI wetlands are no longer
present, and that development of the remainder of the property can proceed without Section 404 permitting.
Figures
Figure 1. NWI Wetlands Map.
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Figure 2. Initial Wetlands Mapping by SGM (July 17, 2019).
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Figure 3. Location of Irrigation Laterals, Ditches, and Other Drainages.
From: Alex Nees
Sent: Monday, July 6, 2020 2:02 PM
To: Morse, W Travis CIV USARMY CESPK (USA)
Subject: RE: Scott Contracting's "Rifle Pit #1" project
Thanks Travis,
The contact info for the client is as follows (this will match what is provided on the GarCo permit
application):
Scott Contracting Inc. - Chris Hurley
9200 Mineral Avenue
Centennial, CO 80112
(720) 889 - 4402
churley@scottcontracting.com
Best,
Alex
-----Original Message-----
From: Morse, W Travis CIV USARMY CESPK (USA) <w.travis.morse@usace.army.mil>
Sent: Monday, July 6, 2020 12:26 PM
To: Alex Nees <alexn@sgm-inc.com>
Subject: RE: Scott Contracting's "Rifle Pit #1" project
Hi Alex,
The plan sounds reasonable; however, a formal JD may be unnecessary.
Can you send me the contact info of your client/potential applicant (POC, company, mailing address,
email, telephone) so that I can assign this action a file number?
Sincerely,
Travis Morse
Senior Project Manager
Colorado West Section
U.S. Army Corps of Engineers
400 Rood Avenue, Room 224
Grand Junction, Colorado 81501
(970) 243-1199 ext. 1014
***In response to COVID-19, Regulatory Division staff are teleworking from home or other approved
location. We will do our best to administer the Regulatory Program in an effective and efficient manner.
Priority will be given to health and safety activities and essential infrastructure. Action on your permit
application or other request may be delayed during this emergency. We appreciate your patience over
the next several weeks.***
Please provide us with your feedback by filling out a customer survey at
http://corpsmapu.usace.army.mil/cm_apex/f?p=regulatory_survey
For more information about our program, you can visit our website at
http://www.spk.usace.army.mil/Missions/Regulatory.aspx
-----Original Message-----
From: Alex Nees [mailto:alexn@sgm-inc.com]
Sent: Monday, July 6, 2020 11:40 AM
To: Morse, W Travis CIV USARMY CESPK (USA) <w.travis.morse@usace.army.mil>
Subject: [Non-DoD Source] Scott Contracting's "Rifle Pit #1" project
Hi Travis,
As we discussed briefly on the phone last week (July 2), Scott Contracting is proceeding with their plans
to develop a gravel pit at Mamm Creek, between the Interstate and the Colorado River (KMZ of the site
attached). The property is Parcel 217908300103.
Scott is in the process of submitting their development permit application to Garfield County; this will be
a Major Impact Review per GarCo guidelines. As part of that review process, Glenn Hartmann noted that
GarCo would send the application to you for review, and asked that we notify you. The application
includes a memo that addresses that differences between USACE jurisdiction and GarCo Waterbody
protections, and discusses in detail the information I summarize below.
* Based on a delineation I completed in the summer of 2019, significant portions of the western
end of the property have surface water and display conditions consistent with wetland character (map
attached). As we discussed, Scott has completed hydrologic modeling and reviewed existing drill core
data which strongly indicate that the surface water is perched on a clay plan no deeper than 3 feet, and
is underlain by approximately 4 feet of dry gravel before groundwater is encountered at a depth of
approximately 7 feet. The only known source of surface water on the property is the Last Chance
tailwater ditch and associated laterals, which currently discharge onto and/or traverse the property.
Therefore the assumption is that the surface water is derived from agricultural sources.
* Scott proposes to begin development of the gravel mine in the eastern portion of the property,
outside the areas of wetland vegetation. They will reroute the Last Chance Ditch and all laterals to cease
the discharge of tailwater onto the property. Tailwaters will be transported around the perimeter of the
property to the existing tailwater ditch and thence to the Colorado River. Scott expects that the
combination of (a) stopping the surface discharge of irrigation water onto the site, and (b) depressing
groundwater by pit dewatering will remove all feasible sources of water from the wetlands on the site,
resulting in an immediate loss of wetland hydrology and a subsequent loss of hydrophytic vegetation,
thus providing evidence of the agriculturally-induced nature of these wetlands.
* Scott proposes to monitor the wetland conditions on a quarterly basis once initial development
begins (essentially completing repeated delineations), to track the response of the wetlands to the
development activity. These quarterly monitoring reports would be completed by SGM and shared with
Scott and the USACE. If conditions respond as is expected, and the wetlands lose jurisdictional character,
Scott would request a formal Jurisdictional Determination from the USACE, and then expand the mining
area to include the majority of the parcel.
Please let me know if you have any questions/concerns, or would like any additional information
pending the finalization of Scott’s land use change application to GarCo.
Best,
Alex Nees
Senior Ecologist
<Blockedhttp://www.sgm-inc.com/>
<Blockedhttps://www.facebook.com/#!/SGM.Inc>
<Blockedhttps://www.linkedin.com/company/1673955?trk=prof-exp-company-name>
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 1 (P1)
Photo Point 2 (P2)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 2:
Origin of PPL. Inland salt grass,
sand dropseed, poverty weed,
small amounts of tall wheat
grass, etc. Clearly grazed, no
hydrology.
PPL Option 2:
Fenceline ditch conditions. No
evidence of significant
maintenance or use of tailwater
ditch on Shideler property.
Ditch shows no evidence of
flow, and is dominated by
smooth wheat grass and
English plantain (Plantago
lanceolata). Maintained ditch
on opposite side of fence is on
Colorado River Ranch property.
Outside of ditch boundaries,
vegetation is typical mesic
pasture, with no potential for
wetland occurrence.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 3 (P3)
Photo Point 4 (P4)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 2:
Problem Area #1, a small
ponding site supporting
patches of reedgrass and
Juncus balticus. The green
vegetation is predominantly
smooth brome. The only
possible wetland zone is the
pooling area and small patches
of reedgrass and Juncus.
PPL Option 2:
Potential crossing site b/w
problem areas. This has no
potentially-jurisdictional
features. Note gap between
two patches of Juncus,
connecting upland saltbrush
scrub in immediate foreground
with upland saltbrush scrub in
near background.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 5 (P5)
Photo Point 6 (P6)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 2:
Crossing of old ditch channel
with upland character. No
hydrology, vegetation
dominated by tall wheatgrass,
rabbitbrush, greasewood.
PPL Option 2:
Problem area #3 has ponding
water supporting reedgrass and
Russian olive, plus a small
amount of cattail in the ditch.
Also many fences and gates to
maintain.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 7 (P7)
Photo Point 8 (P8)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 1:
Representative conditions on
the shoulder of the frontage
road. Clearly upland/pipeline
right-of-way reclamation
vegetation. Note existing Ursa
Energy pipeline. Vegetation is
drill-seeded reclamation
grasses, dominated by tall
wheatgrass, with smaller
components of dropseed and
saltgrass.
PPL Option 1:
Note hydrophytic vegetation
within pasture fence and
extending slightly beyond
pasture fence, including Juncus
and milkweed. Note right-of-
way/reclamation upland
species on viewer's right.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 9 (P9)
Photo Point 10 (P10)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 1:
Problem Area #4 has
Phragmites growing across the
right of way. Initial investigation
suggests minimal likelihood of
wetland occurrence. No
apparent source of hydrology,
but the vegetation has clearly
reestablished after the
installation of the earth the gas
pipeline. WWDF datapoint
"DP-2" indicates presence of
hydric soils but no clear
hydrology.
PPL Option 1:
Ditch lateral (Last Chance
Ditch?) has clearly has been
bored by previous pipeline
installation. Ditch prism
dimensions are 46 inches at the
top, 12 inches at the bottom, 18
inches deep. Significant
sediment accumulation in the
prism in some areas are
reducing the total capacity.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 11 (P11)
Photo Point 12 (P12)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 1&2:
Problem Area #5 is a ponding
area, pretty clear that water
source is derived from
discharge of tailwater Ditch at
immediate far right. Could be
skirted on the southeast.
PPL Option 1&2:
Lateral ditch, running alongside
Fenceline. Note ditch elevated
above the pasture field at left
and the ROW at right. Ideally
pipeline would be installed in
shoulder on either side of ditch
to take advantage of elevated
topography. Ditch prism as
previously recorded, 42" x 18" x
12"
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 13 (P13)
Photo Point 14 (P14)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
PPL Option 1&2:
Pipeline could also be installed
next to ditch in the pasture.
Note that powerlines would
interfere with installing pipeline
in the south shoulder of the
ditch. Best option may remain
routing through right-of-way
on viewer's right
PPL Option 1&2:
Conditions of proposed
discharge point. Artificial ditch,
artificial turn-out, then ditch
transitions immediately
downstream to an excavation in
native soil. Ditch prism is 46" x
18"x16" at bottom. 6" vertical
wall rises from the top of the
prism. Discharges into a splitter
that is 24” x 24" square. Splitter
discharges into lateral pictured
in P12 and P13, and to an
earthen ditch that is
approximately 2 feet deep and
5 feet wide (viewer's far right
foreground).
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 15 (P15)
Photo Point 16 (P16)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
Existing ditch is clearly
artificially excavated and
subject to ongoing use and
maintenance. Note ditch
excavation material piled on
viewer's right.
Double crossing of wetland
channels. Near-view crossing is
culverted, far crossing is a low-
water crossing (with visible
open water).
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 17 (P17)
Photo Point 18 (P18)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
Culverted road crossing, with
wetland channel on both sides.
Pipeline could be installed in
the road bad using existing
culvert. Road bed is non-
wetland, due to elevation
approximately 6 feet above
surrounding wetland areas.
Clear evidence of naturally
occurring shallow ground
water, visible in exposed gravel
beds. Strong evidence that
other wetland areas on the
property are supported by
natural ground water as well,
and therefore jurisdictional.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 19 (P19)
Photo Point 20 (P20)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
Typical conditions along
Colorado River, within the
Shideler property. No indication
of any artificial turn-out,
headgate, or discharge
structures.
Relic highwater channel. No
indications of recent flow from
Colorado River, no identifiable
ordinary high watermark, no
defined channel or change in
vegetation. But topography and
sand deposits indicate at least
occasional flow here.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 21 (P21)
Photo Point 22 (P22)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
Typical conditions along the
western portion of riverbank on
Shideler property. Generally,
upland conditions extend to
the edge of the ordinary high
watermark. There is no natural
or artificial discharge from the
Shideler property into the river
at any point.
This feature appears to be a
naturally-occurring slough
drainage, supported by shallow
groundwater derived from the
River's water table. Surface
water flow evident at the time
of investigation. Photo taken
looking generally east from the
Shideler property line.
PHOTO LOG
Project Name:Site Location:Date:
Photo Point 23 (P23)
Photo Point 24 (P24)
Nov 3, 2020Shideler Property, CO HWY 346, Silt, CO 81652Rifle Pit #1, Dewatering PPL
routing assessment
Muskrat dam has plugged an
existing culvert on what
appears to be the Bernudy
Ditch. Dam is currently
diverting water away from
Bernudy Ditch on the Colorado
River Ranch property, and into
the unnamed native channel
shown in P22. This appears
temporary; Bernudy Ditch
appears to be used/maintained
by Colorado River Ranch.
Powerline access road, taken
looking south. The access road
corridor is free from wetlands
until the culvert crossings are
reached (shown in P16 & P17).
Proposed PipelineOption #1Put Pipeline between fenceand CR 346
DP-1
DP-2
Problem Area #1
Problem Area #2
Problem Area #5
Problem Area #3
Problem Area #4
Ditch currently being used
Potential Crossing
Proposed PipelineOptionBury Pipeline along existingTwo-Track Road
Proposed PipelineOption #2
ERPESTAD,GARY L &JOAN H
SHUSTER,PATRICK L& TONI M
KANCILIA, H D& LESLIE MARIE
SCOTTCONTRACTINGINC
REX ROBINSONRANCH LLC &
SHIDELEROSALLLP
GYPSUMRANCHCO LLC
ISLANDPARK LLC
COLORADORIVERRANCH, LLC
WILLEY,JOSEPH O
WARD, CODY& AMANDA
SHIDELEROSALLLP
NORTH HANGSRANCH LLC
STATE OF COLORADODIVISION OFWILDLIFE
ASPIRIENTERPRISESLLC
RisingSunDitch
Colorado
Ri
v
er
Last Chance Ditch
Last Chanc
e
Dit
c
h
P2
P12
P7
P20
P10
P18
P21
P4
P13
P1
P8
P24
P22
P23
P19
P17
P16
P3
P15
P5
Legend
SCI PropertyGarfield County ParcelsProposed Pipeline Location Option #1Proposed Pipeline Location Option #2Ditch currently being used
Flow DirectionPhoto PointPotential Crossing
Problem Area
WoUS Data PointNHD
Artificial Path
Canal/DitchStream/River
Ephemeral Stream
Intermittent StreamPerennial Stream
Proposed PipelineOption #1Put Pipeline between fenceand CR 346
DP-1
DP-2
Problem Area #1
Problem Area #2
Problem Area #5
Problem Area #3
Problem Area #4
Potential Crossing
Proposed PipelineOption #2
SCOTTCONTRACTINGINC
SHIDELEROSALLLP
GYPSUMRANCHCO LLC
COLORADORIVERRANCH, LLC
SHIDELEROSALLLP
P2
P12
P7
P10
P4
P13
P1
P8
P3
P5
Legend
SCI PropertyGarfield County ParcelsProposed Pipeline Location Option #1Proposed Pipeline Location Option #2Ditch currently being used
Flow DirectionPhoto PointPotential Crossing
Problem Area
WoUS Data PointNHD
Artificial Path
Canal/DitchStream/River
Ephemeral Stream
Intermittent StreamPerennial Stream
DP-1
Ditch currently being used
Proposed PipelineOptionBury Pipeline along existingTwo-Track Road
COLORADORIVERRANCH, LLC
SHIDELEROSALLLP
NORTH HANGSRANCH LLC
Colorado River P20
P18
P21
P24
P22
P23
P19
P17
P16
P15
Legend
SCI PropertyGarfield County ParcelsProposed Pipeline Location Option #1Proposed Pipeline Location Option #2Ditch currently being used
Flow DirectionPhoto PointPotential Crossing
Problem Area
WoUS Data PointNHD
Artificial Path
Canal/DitchStream/River
Ephemeral Stream
Intermittent StreamPerennial Stream
SCOTTCONTRACTINGINC
SHIDELEROSALLLP
GYPSUMRANCHCO LLC
COLORADORIVERRANCH, LLC
SHIDELEROSALLLP
ASPIRIENTERPRISESLLC
DP-1
DP-2
DP-3
DP-4
DP-6
DP-5
Test pit dry
Possibleoutfall?
Test pit dry
P13
P19
P1
P8
P23
P22
P24
P12
P7
P2
P5
P15
P16
P17
P3
P20
P10
P18
P21
P4
Legend
Data PointPhoto/CommentWaters
Proposed Pipeline
Alternative Pipeline RouteWetlandProblem Area
Wetland Slough/Ditch Complex
SCI PropertyGarfield County Parcels
Hahn Water Resources, llc
MEMORANDUM
June 3, 2020
TO: Angie Fowler, SGM
FROM: Bill Hahn, P.G.
SUBJECT: Rifle Pit Estimate of Pit Inflows
Angie,
Following are my findings on the probable rates of pit inflow / dewatering requirements
related to dewatering of a proposed sand and gravel mine known as the Rifle Pit No. 1. My
investigation was completed in August 2019 and summarized in a letter report to you. As you
know, my investigation focused on the potential impacts of dewatering on adjacent wetlands
rather than on the specific elements and design of the dewatering system.
MODFLOW-2000 was selected as the modeling platform. MODFLOW is a three
dimensional, finite-difference groundwater model developed by the U. S. Geological Survey.
The model was used to estimate water level impacts from pit dewatering with an emphasis on
water level change that would result from dewatering rather than on a specific dewatering
system and its performance. Given the absence of site-specific information on aquifer
properties, there is significant uncertainty in the inflow rates that were simulated by the
model.
With these facts in mind, the model predicted a pit inflow rate of about 7 cfs (3,000 gpm)
under steady-state conditions. This rate will vary as a function of time, the pace of the
mining, the depth and length of the dewatering trench (or if wells are used, the spacing and
depth of the wells), the relative influence of boundary conditions, and several other factors.