HomeMy WebLinkAbout1.00 ApplicationGARFIELD COUNTY LAND USE PERMIT APPLICATION
RIFLE PIT #1
IHC SCOTT (SCOTT CONTRACTING INC.)
March 30, 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 March 2021
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TABLE OF CONTENTS
1.0 General Project Narrative and Information 1-1
1.1 Project Overview 1-1
Mining Equipment 1-1
Staffing 1-3
General Schedule of Operations 1-3
Access 1-3
Request for Waivers 1-4
Water Supply and Distribution Plan Standard Waiver 1-4
Wastewater Treatment Plan Standard Waiver 1-4
Industrial Facility 100-Foot Setback 1-5
Wetlands Setback 1-5
Comprehensive Plan 1-5
Mining Plan and Schedule of Operations 1-5
Site Development and Grading (Phase 1) 1-5
Mining Preparation (Phase 2) 1-9
Mining Extraction (Phase 3 – in 2 Stages) 1-9
Reclamation (Phase 4) 1-12
1.2 Regulatory Provisions Applicant is Required to Address 1-12
2.0 Submittal Requirements 2-1
2.1 General Application Materials 2-1
2.2 Vicinity Map and Site Plan 2-1
2.3 Grading and Drainage Plan 2-1
2.4 Landscaping Plan 2-1
2.5 Impact Analysis 2-1
2.6 Development Agreement / Improvements 2-1
2.7 Basic Traffic Study 2-2
2.8 Water Supply / Distribution Plan 2-2
Waiver Request Justification (provided to Garfield County Public Health) 2-2
Well Permitting Process and Schedule 2-4
2.9 Wastewater Treatment Plan 2-5
Waiver Request Justification (provided to Garfield County Public Health) 2-5
2.10 Garfield County LUDC: Article 7 – Standards 2-6
Division 1 – General Approval Standards 2-6
Division 2 – General Resource Protection Standards 2-8
Division 3 – Site Planning and Development Standards 2-14
2.11 Floodplain Development Analysis 2-14
IHC Scott – Rifle Gravel Pit #1 March 2021
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2.12 Gravel Extraction Activities 2-14
Water Quantity and Quality Impacts/Floodplain Impacts 2-15
Summary of Augmentation Plan for Dewatering Operations 2-15
Air Quality 2-16
Noise/Vibration 2-16
Visual Mitigation 2-19
County Road System 2-19
Compatibility with Surrounding Land Uses 2-20
Revegetation / Reclamation 2-20
Description and Types of Reclamation 2-20
Post-Mining Land Use 2-20
Implementation of the Reclamation Plan 2-22
Topsoil Segregation, Preservation, and Replacement 2-22
Final Grading 2-22
Seeding 2-22
Temporary Seed Mix 2-22
Long-Term/Permanent Seed Mix 2-22
Fertilization 2-23
Revegetation 2-23
Topsoiling 2-23
Revegetation Success Criteria 2-23
Noxious Weed Control 2-23
Reclamation Plan Schedule 2-24
Previously Disturbed/Unnecessary Areas 2-24
Active Mining Areas 2-24
Monitoring Reclamation Success 2-24
Enforcement 2-25
3.0 Referral Agency Coordination 3-1
LIST OF TABLES
Table 1. Estimated Areas of Disturbance to Support Gravel Mining 1-1
Table 2. Typical Equipment List 1-3
Table 3. Sound Monitoring Data 2-19
LIST OF FIGURES
Figure 1. Project Overview 1-2
Figure 2. Estimated Drawdown of Groundwater Levels following 1 year of Continuous Dewatering (estimated 3
wells) 1-8
Figure 3. Stage 1 Mining Plan Details 1-10
Figure 4. Stage 2 Mining Plan Details 1-11
Figure 5. Vicinity Map 2-1
Figure 6. Ambient Noise Measurements at Rifle Pit #1 Property on September 30, 2020. 2-17
IHC Scott – Rifle Gravel Pit #1 March 2021
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Figure 7. Noise Measurements from the Meeker, Colorado Scott Operations 2-18
Figure 8. Reclamation Plan 2-21
LIST OF APPENDICES
Appendix A
Forms
Appendix B
Traffic Study
Access Permit
Notice-to-Proceed
Appendix C
Appendix D
Grading and Drainage Plan
Appendix E
Impact Analysis
Wetlands Memo & Dewatering Plan
Appendix F
Noxious Weed Survey
Appendix G
Floodplain Development Analyses
IHC Scott – Rifle Gravel Pit #1 March 2021
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1.0 General Project Narrative and Information
IHC Scott (Scott) [formerly Scott Contracting, Inc. (SCI)] is seeking a Land Use Change Permit
for a commercial gravel pit (Rifle Gravel Pit #1) to be located on a 58.7-acre parcel just north
of Interstate 70 (I-70), approximately 1-mile northeast of the Rifle Airport (Figure 1). The
proposed gravel mining operations will occur in four phases. The phases are as follows:
· Site development and grading (Phase 1)
· Mining preparation (Phase 2)
· Mining extraction (Phase 3 – in two stages, Stage 1, and Stage 2, limited to non-
wetland areas)
· Reclamation (Phase 4)
The mining extraction areas associated with Phase 3, Stage 1 and Stage 2, has approximately
1-2 million tons of minable material that will be extracted over four years. These materials are
anticipated to support various construction projects for future Garfield County (County) and
Colorado Department of Transportation (CDOT) projects. The estimated area of disturbance
during Stage 1 is 18.04 acres and 8.70 acres during Stage 2.
A 12” dewatering pipeline will be installed during Phase 1 to collect water from the dewatering
wells and convey it to the Colorado River. The land disturbance associated with the
dewatering pipeline is temporary and estimated at 0.96 acres (3,622 linear feet with a 5-foot
offset on both sides of the pipeline).
The total estimated planned excavation area is provided in Table 1 and amounts to
approximately 29.30 acres. Appendix C includes the Drawings depicting additional details and
information associated with this proposed mining activity.
Table 1. Estimated Areas of Disturbance to Support Gravel Mining
Mining Operation Stage Area
(acres)
Dewatering Pipeline Construction (temporary disturbance) (Phase 1) 0.96
Stage 1 (Limits of Disturbance) (Phase 3) 18.04
Stage 2 (Limits of Disturbance) (Phase 3) 8.70
Operations Area (Phase 1) 1.6
Total 29.30
This document includes the information required by the County Planning Staff (Staff) in their
Pre-Application Conference Summary (Appendix A), per the Garfield County Land Use and
Development Code (LUDC).
1.1 Project Overview
The following subsections highlight the activities and major elements of the project.
Mining Equipment
Various types of heavy equipment will be used for the mining and dewatering activities during
the four phases of the project including, but not limited to: a work trailer, screening, and wash
IHC Scott – Rifle Gravel Pit #1 March 2021 1-2 Figure 1. Project Overview
IHC Scott – Rifle Gravel Pit #1 March 2021
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equipment; heavy excavation equipment; and seeding and mulching equipment for
reclamation operations. Table 2 lists typical equipment (and make) used at Scott’s gravel
mining operations.
Explosives will not be used during mining or reclamation of the property.
Table 2. Typical Equipment List
Equipment Make
Generator CAT
Jaw Crusher CED
Material Belt SUP
Screen Plant Tee
Reticulate Belt SUP
Cone Crusher Tee
Stacker SUP
Parts Trailer
Pump (Dewatering) Godwin
Water Truck Peco
Water Tower (12k) Mega
Fuel Tank (10k) SC Fuels
Bulldozer CAT
Excavator Volvo/CAT
Sheepsfoot Bomag
Scraper/Grader CAT
Feeder FAB
Stacker SUP
Staffing
Three to five employees will be present on the site. The specific numbers will vary depending
upon the mining phase.
General Schedule of Operations
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.
Access
Access to the property is via I-70 North frontage road via Mamm Creek Road (Figure 1). Mr.
Dale Stephens, Garfield County Road and Bridge Department, confirmed that the access
permit for this project is through CDOT. Appendix B includes a copy of the signed CDOT State
Highway Access Permit.
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Request for Waivers
Scott is requesting four waivers: 1) the Water Supply and Distribution Plan standard (Article
7: 7-104 and 7-105); 2) the Wastewater Treatment Plan standard (Article 7: 7-104 and 7-105);
3) the 100-foot setback requirement for industrial facilities (Article 7-1001); and 4) the
Wetlands setback requirement (Section 4-118). Accompanying explanations as to why the
waivers from these standards are warranted are included with this application and were part
of the agency referral comment resolution process.
Water Supply and Distribution Plan Standard Waiver
The Garfield County Public Health Department, Mr. Edward R. “Ted” White, (in a letter dated
August 27, 2020 to Mr. Patrick Waller) communicated the following specific to the Potable
Water waiver (see letter in Appendix H):
“The location of the proposed project does not facilitate water service from either the
Town of Silt or the City of Rifle. Additionally, the nature of development and dewatering
of the gravel pit does not facilitate the drilling of a well for potable water use. The
applicant proposes to purchase water for on-site use from a bulk water seller and haul
to the site for storage and use. We believe that this proposed variance is acceptable,
provided that adequate hand washing facilities, in addition to the mentioned water
bottle filling are provided to employees during the proposed 12-hour days of operation.
We would recommend that annual testing of the water in the storage facility on-site
occur to ensure that water quality is maintained throughout the project. Additionally,
we would recommend maintaining invoices from the bulk water purchases on-site in
case an employee develops a water-borne illness, to allow for tracking of the potential
water source. Garfield County Public Health supports this variance request from the
Water Supply and Distribution standard, provided that hand washing stations are
provided, and water quality is tracked.”
In response to this comment, Scott will provide adequate hand-washing facilities and water
bottle filling services to its employees during the daily operations. Water purchases and water
quality documentation will also be retained for the drinking water and hand-washing water
services.
Wastewater Treatment Plan Standard Waiver
The Garfield County Public Health Department, Mr. Edward R. “Ted” White, (in a letter dated
August 27, 2020 to Mr. Patrick Waller) communicated the following specific to the Onsite
Wastewater Treatment Systems (OWTS) waiver (see letter in Appendix H):
“…Due to the nature of the gravel extraction process and this project, we agree that
the construction of a traditional OWTS is not feasible for this project. However, we do
not believe that the use of portable toilets during the five-year extraction phase…is
acceptable from a public health and environment perspective. The use of a “vault-and-
haul” system that utilizes and above-ground holding tank could be used and moved
across the site as the project progresses. We would encourage the applicant to pursue
a different avenue to handle wastewater than the use of portable toilets. We do not
support the granting of this variance request from the Wastewater Treatment Plan
standard, as viable options exist to meet this section”.
IHC Scott – Rifle Gravel Pit #1 March 2021
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Note this comment refers to an old mining plan that was going to develop the entire site in five
stages.
In response to this comment, Scott will contract with a vault-and-haul vendor to provide
wastewater (and hand-washing water) services. Scott will have a trailer outfitted with two
restrooms for staff. This trailer will have one 2,000-gallon tank to capture waste from the toilet
and handwashing facilities. A high-level float alarm will also be installed and notify Scott when
the tank needs to be pumped. The handwashing facilities will be designed to receive potable
water (treated).
Industrial Facility 100-Foot Setback
Scott is requesting a waiver from this standard.
Wetlands Setback
The dewatering permit will cause a temporary disturbance of wetlands. Article 7-203.B
(Structures Permitted in Setback) states that, “Irrigation and water diversion facilities, flood
control structures, culverts, bridges, pipelines, and other reasonable and necessary structures
requiring some disturbance within the 35-foot setback may be permitted”. Hence, Scott
doesn’t believe that a Waiver of Standards applies for the pipeline as the installation of the
pipeline will result in temporary impacts only.
Comprehensive Plan
The property is designated in the County Comprehensive Plan as within the Residential
Medium High Density (2 to <6 acres per dwelling unit) and Silt Urban Growth Area.
Mining Plan and Schedule of Operations
Scott will develop the site and mine sections of the property in four primary phases. Phase 3,
mining extraction, will occur in two stages. The project Drawings are included in Appendix C
and provide additional details associated with this application and the Mining Plan.
Site Development and Grading (Phase 1)
This phase of the project will include minor site grading, vegetation removal and construction
of the site access/driveway. Scott will not disturb the tailwater channel in its existing location
and implement Best Management Practices (BMPs) to prevent mining operations from
discharging into or comingling with these waters. Scott will install a low-water crossing at the
existing tailwater culvert crossing or collect the water in a pipe.
The existing topsoil will be stripped and used for the required 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 and will help
control noise produced during operation. These berms will serve many purposes but specific
to drainage and erosion control they will prevent runoff of stormwater and intercept
groundwater off site and protect the operations from the influence and flooding by the
Colorado River.
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Note overburden materials across the site vary. The boring holes indicate the overburden
depth can vary from 1 foot to 2.5 feet. Appendix C includes the typical cross-sections at the
boring holes.
The mine will use conventional earth moving equipment to stockpile topsoil and gravel
including, but not limited to a bulldozer, track-hoe, and a 35-ton haul truck.
IHC Scott – Rifle Gravel Pit #1 March 2021
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Water Handling and Dewatering
Stormwater Management
Scott will apply for coverage under Permit No. COR400000, CDPS General Permit (for)
Stormwater Discharges Associated with Construction Activity at least 10 days prior to the
commencement of construction activities disturbing greater than or equal to 1 acre. This
permit has several requirements that address water quality and stormwater management,
including monitoring and reporting, and the development and implementation of a Stormwater
Management Plan (SWMP).
During the initial stages of mining, Scott will not disturb the tailwater channel in its existing
location and implement BMPs to prevent mining operations from discharging into or
commingling with these waters. Scott will install a low-water crossing at the existing tailwater
channel crossing or collect the channel in a pipe.
Dewatering
Scott will also apply for coverage under Permit No. COG603000 (Discharges Associated with
Subterranean Dewatering or Well Development) or Permit No. COG608000 (Discharges to
Surface Water from Well Development and Pumping Test Activities) to manage dewatered
water. The specific permit will be determined once the water is sampled and analyzed.
Scott negotiated a temporary license agreement with the owner of the neighboring Shideler
property (Parcel 217908100527) to the east that will allow Scott to bury a 12” dewatering
pipeline that will collect and convey pumped dewatered water to the Colorado River (Appendix
C Drawings). This pipeline will have an energy dissipation structure upstream of the discharge
point to the Colorado River and an armored outfall to prevent erosion and sedimentation
discharges into the Colorado River.
The trenching and installation of the proposed dewatering pipeline will create temporary
impacts to federally jurisdictional wetlands located on the Shideler property (Parcel
217908100527), and will also require a permanent outfall structure on the bank of the
Colorado River, which will constitute a permanent impact to that jurisdictional water. A range
of alternatives has been considered for this project and every effort has been made to avoid
the discharge of dredged or fill material into waters of the United States. However, there are
no practicable alternatives that avoid a minor and temporary filling of wetlands, which have
been minimized to the extent possible by careful selection of the proposed pipeline route.
An aquatic resources report and wetland delineation will be submitted to the Army Corps of
Engineers (ACOE) in support of a nationwide permit application 39 (NWP 39) for Commercial
and Institutional Developments. The NWP 39 application will encompass the pit mining stages
(Stages 1-2) and the dewatering pipeline. All impacts from the dewatering pipeline are
temporary; in accordance with NWP 39 conditions, during installation in wetland areas heavy
equipment will work on mats to minimize surface disturbance, and topsoil will be segregated
and reapplied following pipeline installation. No changes are proposed to the existing
hydrologic conditions on the Shideler property; therefore, the wetland conditions will quickly
re-establish in the pipeline route. The NWP 39 will be acquired prior to construction.
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Coverage under a Nationwide Permit No. 7 will also be obtained for the outfall to the Colorado
River. Scott submitted a Watershed Permit Application to the City of Rifle to address the
dewatering discharge within their Watershed Protection Area.
Dewatering Pumping Information
The rate of groundwater discharge (pumping) associated with dewatering is expected to
approach about 7 cfs. Mr. Bill Hahn (Hahn Water Resources, LLC) predicted the anticipated
dewatering operations (through modeling); however, this is an estimate based upon borings
and groundwater level data. Mr. Hahn presented one possible dewatering configuration that
might be employed for dewatering associated with the initial stages of mining. Figure 2 shows
the estimated drawdown following one-year of dewatering using 3 wells in the vicinity of the
Stage 1 and Stage 2 mining limits.
Figure 2. Estimated Drawdown of Groundwater Levels following 1 year of Continuous
Dewatering (estimated 3 wells)
In this case, the dewatering might be accomplished using 3 wells plus temporary drains and
pumps to capture incidental inflows, pumping at a combined rate of about 3 cfs. The number
and size of the dewatering pump(s) will be determined once mining commences, however,
Mr. Hahn assumed the wells would be drilled to a depth of 30 feet, constructed with nominal
IHC Scott – Rifle Gravel Pit #1 March 2021
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8-inch to 12-inch diameter casing and screen, equipped with 10 horsepower pumps and
motors to pump 400 to 700 gallons per minute (gpm) and 2 to 4 centrifugal ditch pumps
capable of pumping up to several hundred gpm of incidental pit inflows.
The dewatering permit terms and conditions will require that this information be documented
in the application. Appendix C includes a copy of Mr. Hahn’s reports.
Mining Preparation (Phase 2)
This phase of the project will include mobilization of the heavy equipment, work trailer,
screening and wash equipment, and major site grading to prepare the site for mining activities.
This phase of the project will include additional minor site grading and vegetation removal, as
needed. Equipment for this phase will include, but not be limited to, a bulldozer, track-hoe,
and a 35-ton haul truck.
Water Handling and Dewatering
Phase 1 dewatering activities will continue throughout this phase. No additional water
diversions nor impoundments will be required during this phase.
Mining Extraction (Phase 3 – in 2 Stages)
Initial mining extraction operations will take place in 2 extraction stages and include the areas
east of the delineated wetlands. Fencing will be installed at least 10-feet away from the
tailwater channel and wetlands to prevent disturbance of these resources.
Stage 1 of the mining extraction operation will start in the southeastern quadrant of the site,
depicted in the Drawings in Appendix C (see also Figure 3). At this location, the crusher will
be placed at existing grade as excavation proceeds down to the lowest elevation of the gravel.
When enough material has been excavated in Stage 1, the crusher will be moved to the mining
pit floor. Stage 2 will take place in the northeastern quadrant of the property (See Drawings in
Appendix C or Figure 4).
Scott will also monitor the response of the delineated wetlands on the property over the course
of Phase 3 to determine if the wetlands are supported entirely by agricultural water (i.e. non-
jurisdictional). If the wetlands are determined to be non-jurisdictional, Scott intends to submit
a minor amendment to the Garfield County Land Use Change Permit to allow for expanded
mining in the future.
It should be noted that the dewatering pipeline on the Shideler property will already be
installed and the associated disturbance will be revegetated during mining extraction.
The location of the mining equipment in the bottom of the pit will support mitigation of the
mining noise and dust. All stockpiling of material at this point also be done at this level.
Stockpiling and Overburden Handling
This phase of the project will include stockpiling of material for screening, washing and
crushing processes. Sheets C5 and C6 in the Drawings (Appendix C) or Figure 3 and Figure
4 to see the approximate location of the stockpiles. Equipment for this phase will include, but
not be limited to, a bulldozer, track-hoe, and a 35-ton haul truck.
IHC Scott – Rifle Gravel Pit #1 March 2021 1-10 Figure 3. Stage 1 Mining Plan Details
IHC Scott – Rifle Gravel Pit #1 March 2021 1-11 Figure 4. Stage 2 Mining Plan Details
IHC Scott – Rifle Gravel Pit #1 March 2021
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Water Handling and Dewatering
Phase 1 dewatering activities will continue throughout this phase. Any water encountered at
the bottom of the pit during this phase will be intercepted by a buried perforated pipe
(estimated at three feet below the mining floor). It is assumed that any water captured in the
perforated pipe will be pumped by the dewatering well.
Scott will comply with the State Engineer Office’s (SEO) rules and regulations regarding any
water depletions that may also occur during mining operations from water lost with mined
aggregate and water used for dust suppression.
Reclamation (Phase 4)
The reclamation of the property will be completed as each mining stage is completed, per
Sheet C8 of the Drawings (Appendix C) and restored back to natural conditions upon
completion of each stage of mining activities. Areas disturbed during development shall be
restored with natural-appearing landforms that blend with the adjacent undisturbed
topography within 90 days of completion to meet County standards. Scott will start the
reclamation process as soon as mining progresses throughout the site. After each mining
phase is completed, Scott will start backfilling pits with excess dirt and unused material. The
pits will not be filled in completely as part of the reclamation plan is to create a recreational
pond. See Sheet C8 in Appendix C for proposed pond location.
Areas disturbed by grading will be contoured so they can be revegetated and stabilize the
surface from erosion. Trees, shrubs, bushy-type vegetation, and approved grasses will be
planted as approved by the Natural Resource Conservation Service (NRCS) and/or County.
Scott will achieve the required reclamation of the affected land per the Garfield County Land
Use Permitting and seeding regulations using existing and available equipment. The primary
reason for this goal is to minimize dust and erosion of the property and restore the site back
to its natural conditions to the extent practicable.
Sheet C8, Reclamation Plan, found in Appendix C, depicts the amount of acreage proposed
for each reclamation activity. All reclamation will occur with specified equipment and methods
for attaining successful revegetation of the property. It is assumed that an 18.4-acre pond will
be present post-mining.
1.2 Regulatory Provisions Applicant is Required to Address
This application was prepared according to the following regulatory provisions:
· Garfield County Comprehensive Plan, 2030
· Garfield County Land Use and Development Code, as amended
· Section 4-101 – Common Review Procedures
· Section 4-105 – Major Impact Review
· Section 4-203 – Submittal Requirements
· Applicable Provisions from Article 7, Standards (Article 7, Divisions 1-3; Section 7-
1001 Industrial Use; and Section 7-1002 Gravel Extraction)
· City of Rifle
· Town of Silt
· Colorado River Fire Rescue
IHC Scott – Rifle Gravel Pit #1 March 2021
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· CDPHE Air Quality
· Division of Reclamation Mining and Safety (DRMS)
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2.0 Submittal Requirements
Garfield County Planning Staff provided a list of the Submittal Requirements for this Major
Impact Extraction, Gravel project. This section is organized per those requirements.
2.1 General Application Materials
Section 4-203.B. of the LUDC lists forms and agreements that are required for the Permit
Application, including:
· Payment Agreement Form
· Proof of Ownership (title work, copy of deed)
· Statement of Authority Form
· Names and Mailing Addresses (properties within 200 feet)
· Mineral Rights Ownership
· Pre-Application Summary
Signed copies of these forms and agreements are included in Appendix A.
2.2 Vicinity Map and Site Plan
Section 7-203.C. of the LUDC outlines various features that need to be included in a Vicinity
map within a radius of approximately 3 miles of the project. Figure 5 depicts the Vicinity map.
Section 4-203.D. outlines various features that need to be included in the Site Plan. Figures
1 through 3 depict various features associated with the Rifle Pit #1. Additionally, Appendix C
includes the project Drawings that provide additional details.
2.3 Grading and Drainage Plan
Section 4-203.E. of the LUDC outlines the elements of the Grading and Drainage Plan.
Appendix D.
2.4 Landscaping Plan
Section 4.203.F. of the LUDC outlines the Landscaping Plan requirements. This section of the
LUDC also mentions that industrial uses are exempt from landscaping standards. Even
though this is will be an industrial use, a reclamation and revegetation plan has been
developed for the site. Please refer to Section 2.12.7 Revegetation/Reclamation regarding
post-mining reclamation plans.
2.5 Impact Analysis
Section 4-203.G. of the LUDC outlines the Impact Analysis requirements. This can be found
in Appendix E.
2.6 Development Agreement / Improvements
Section 4-203.J, K. of the LUDC outline the Development Agreement / Improvements
Agreement requirements. Scott believes there are no vesting issues and identified
IHC Scott – Rifle Gravel Pit #1 March 2021 2-1 Figure 5. Vicinity Map
IHC Scott – Rifle Gravel Pit #1 March 2021
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improvements to the North Frontage Road have been permitting and will commence upon
approval of this permit application.
2.7 Basic Traffic Study
Section 4-203. L. of the LUDC outlines the Traffic Study – Basic Traffic Study requirements.
A copy of the CDOT-approved Traffic Impact Study is included Appendix B. The I-70 N
Frontage Road (also known as CR 346) will be used to access the site (Figure 1). The County
Road and Bridge staff confirmed that any increased traffic along this road are to be addressed
using the CDOT process.
2.8 Water Supply / Distribution Plan
Scott is requesting a waiver from this standard.
The Garfield County Public Health Department, Mr. Edward R. “Ted” White, (in a letter dated
August 27, 2020 to Mr. Patrick Waller) communicated the following specific to the Potable
Water waiver (see letter in Appendix H):
“The location of the proposed project does not facilitate water service from either the
Town of Silt or the City of Rifle. Additionally, the nature of development and dewatering
of the gravel pit does not facilitate the drilling of a well for potable water use. The
applicant proposes to purchase water for on-site use from a bulk water seller and haul
to the site for storage and use. We believe that this proposed variance is acceptable,
provided that adequate hand washing facilities, in addition to the mentioned water
bottle filling are provided to employees during the proposed 12-hour days of operation.
We would recommend that annual testing of the water in the storage facility on-site
occur to ensure that water quality is maintained throughout the project. Additionally,
we would recommend maintaining invoices from the bulk water purchases on-site in
case an employee develops a water-borne illness, to allow for tracking of the potential
water source. Garfield County Public Health supports this variance request from the
Water Supply and Distribution standard, provided that hand washing stations are
provided, and water quality is tracked.”
In response to this comment, Scott will provide adequate hand-washing facilities and water
bottle filling services to its employees during the daily operations. Water purchases and water
quality documentation will also be retained for the drinking water and hand-washing water
services.
Waiver Request Justification (provided to Garfield County Public Health)
Justification for this request are addressed per the requirements outlined in Section 4-203.M.
of the LUDC, as applicable.
Overall, the Rifle Pit property cannot be supplied potable water from City of Rifle or Town of
Silt, as the property is more than a mile from the City of Rifle’s water system and more than a
mile from the Town of Silt’s water system. Scott communicated with City of Rifle and Town of
Silt on October 29, 2019 and confirmed that neither entity could serve the Rifle Pit Property
without significant infrastructure improvements and line extensions.
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Scott also considered drilling a commercial exempt well on the property to supply potable
drinking water supply during mining operations. However, operation of a well is not feasible
for the following reasons:
· Dewatering operations are expected to drop the water level such that a well would not
be able to operate.
· Most potential locations for the well would have to be moved when that portion of the
property is eventually mined.
Because potable water is not available from City of Rifle or Town of Silt and because drilling
a well for potable water on the property is not feasible given the mining plan, Scott is
requesting a waiver for constructing a permanent potable water supply and distribution system
and would like to, instead, haul potable water onto the site to supply employees with potable
water.
· Water for potable uses only.
o Water supply at the Rifle Pit will be for potable uses only.
· Available water and ability to support potable drinking water only (no landscape or
irrigation).
o There will be no landscape irrigation on the Rifle Pit property. As described
above, potable water is not available from City of Rifle or Town of Silt and
drilling a well for potable water on the property is not feasible given the mining
plan. Scott is therefore planning to truck potable water onto the site to supply
employees with potable water. Scott will supply employees with an adequate
amount of potable drinking water (estimated at 15 gallons per shift with five
employees as described in Item 5 below).
· A minimum 4-hour pump test will be performed on the well. The results of the pump
test will be analyzed and summarized in a report, including basic well data (size, depth,
static water level, aquifer, etc.) pumping rate, draw down recharge, and estimated
long-term yield.
o Potable water will not be provided by a well as this option is not feasible given
the mining operations (as described above). Potable water will be trucked
onsite as described above. Because there will be no well for potable supply,
no pump test will be conducted.
· The report shall be prepared by a qualified professional engineer or ground water
hydrologist and shall include an opinion that the well will be adequate to supply water
for the proposed uses. The report shall also address the impacts to ground water
resources in the area.
o Because potable water will be trucked onsite and not provided by a well (as
described above), there will be no well for potable supply. Because there will
not be a well, no pump test or pump test report is required.
· An estimate of the water supply requirements for the proposed development through
build-out conditions.
o The number of employees on-site will vary from three to a maximum of five,
depending upon the phase of development (See Section 1.1.7). General
Occupational Safety and Health Administration (OSHA) requirements
regarding potable drinking water do not specify a quantity, but State of
California OSHA standards require each employee be provided with one quart
of water per hour during each shift for drinking water, where potable water is
not supplied by plumbing (State of California T8CCR 3395(c)). Hours of
operation will be from 7 a.m. to 7 p.m. 5 days per week. For five employees on
IHC Scott – Rifle Gravel Pit #1 March 2021
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a shift, the potable water demand would be 15 gallons per shift, 75 gallons per
week, and 3,900 gallons per year.
· A description of the physical source of water supply that will be used to serve the
proposed development.
o Because potable water is not available from City of Rifle or Town of Silt and
because drilling a well for potable water on the property is not feasible given
the mining plan, Scott will truck potable water onto the site to supply employees
with potable water. Scott can truck in water to supply a fill station onsite to allow
employees to fill water bottles or could supply potable water with single use
water bottles. Trucked water can be refilled from the Town of Silt bulk water
sales location on South 7th Street (approximately five miles from the Rifle Pit
site. Bulk water can be purchased at a rate of $0.50 per 50 gallons of water
using a pre-paid bulk water card purchased from the Town. The cost of potable
water supply from Town of Silt bulk water is approximately $40 per year for five
employees.
· An estimate of the amount of water yield projected from the proposed water supply
under various hydrologic conditions.
o Because water will be trucked onsite, an analysis of yield under various
hydrologic conditions is not required. Water supply will be available from bulk
water trucked onsite or from bottled water.
· Water conservation measures, if any, that may be implemented within the proposed
development.
o Water will be conserved by not having any landscape or lawn irrigation on the
property. Water will also be conserved by using portable toilets rather than
flush toilets.
· Water demand management measures, if any, that may be implemented to address
hydrologic variations.
o Water demand management measures are not required to address hydrologic
variations. Because water will be trucked onsite, water availability is not
vulnerable to hydrologic variations.
· Fill station – submerged water tank/cistern.
o Potable water trucked onto the site will be provided to employees from a water
fill station. The water fill station will be located in or near the office trailer on the
property. The water fill station will be a closed tank to prevent contamination
and will be filled by trucking water to the site from the bulk water sales location
(such as Town of Silt bulk water sales on South 7th Street). One example of a
jobsite potable water fill station is the PolyJohn FWD3-1000 Water Works 93-
gallon freshwater system, which is designed for providing fresh water at office
trailers and uses a built-in on-demand pump (requires 120-volt hookup). With
five employees (75 gallons of water per week) a 93-gallon tank would need to
be refilled slightly less often than once per week. As a backup, single use gallon
water jugs could be provided.
Well Permitting Process and Schedule
SGM is working collaboratively with Scott and Balcomb and Green, P.C. (water rights
attorneys) in preparing a water court application for this project. Mapping, legal descriptions
for the point of diversion, water demand analysis and water supply availability opinions can
be provided upon request.
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2.9 Wastewater Treatment Plan
Scott is requesting a waiver from this standard.
The Garfield County Public Health Department, Mr. Edward R. “Ted” White, (in a letter dated
August 27, 2020 to Mr. Patrick Waller) communicated the following specific to the Onsite
Wastewater Treatment Systems (OWTS) waiver (see letter in Appendix H):
“…Due to the nature of the gravel extraction process and this project, we agree that
the construction of a traditional OWTS is not feasible for this project. However, we do
not believe that the use of portable toilets during the five-year extraction phase…is
acceptable from a public health and environment perspective. The use of a “vault-and-
haul” system that utilizes and above-ground holding tank could be used and moved
across the site as the project progresses. We would encourage the applicant to pursue
a different avenue to handle wastewater than the use of portable toilets. We do not
support the granting of this variance request from the Wastewater Treatment Plan
standard, as viable options exist to meet this section”.
In response to this comment, Scott will contract with a vault-and-haul vendor to provide
wastewater (and hand-washing water) services. Scott will have a trailer outfitted with two
restrooms for staff. This trailer will have one 2,000-gallon tank to capture waste from the toilet
and handwashing facilities. A high-level float alarm will also be installed and notify Scott when
the tank needs to be pumped. The handwashing facilities will be designed to receive potable
water (treated).
Waiver Request Justification (provided to Garfield County Public Health)
Requirements outlined in Section 4-203.N. of the LUDC are listed and addressed below to
support the request for a waiver.
· If the proposed land use is to be served by an existing public collection system and
treatment facilities, evidence that provision has been made for adequate service to the
proposed land use, in compliance with State and local regulations.
o Because sewer services are not available from City of Rifle or Town of Silt
Scott will provide portable toilets for the wastewater needs.
· If On-Site Wastewater Treatment Systems (OWTS) are proposed.
o No OWTS will be installed and Scott will provide portable toilets for wastewater
needs.
· If a new wastewater treatment facility is proposed.
o Scott will provide portable toilets for wastewater needs. No wastewater
treatment facilities are proposed for this operation.
· Description of the proposed method of financing the collection and treatment facilities.
o Scott will provide portable toilets for wastewater needs. No financing is needed
to support a collection and treatment facility for this proposed operation.
· Wastewater System Design
o Scott will provide portable toilets for wastewater needs. No wastewater
treatment facilities are proposed for this operation.
· Occupancy Restrictions
o Not applicable for this application and proposed development.
· Repair and Maintenance
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o Not applicable for this application and proposed development.
· Public Systems
o Overall, the Rifle Pit property cannot be supplied by the City of Rifle or Town
of Silt, as the property is more than a mile from the City of Rifle’s and the Town
of Silt’s wastewater systems.
· Private Systems
o The Rifle Pit property is located more than one mile from the City of Rifle and
the Town of Silt’s wastewater facilities.
o The suitability of the soils and planned mining operations of the property will
not allow for an OWTS, therefore Scott will be placing portable toilets on-site
to support the sewer needs of the three to five employees. No public use of
these facilities will be allowed.
2.10 Garfield County LUDC: Article 7 – Standards
Division 1 – General Approval Standards
Section 7-101. Zone District Use Regulations
The property is currently zoned Rural, and this application proposes to pursue gravel mining
activities on this property. All requirements of Article 3, Zoning, will be met with this proposal,
through the Major Impact Review – Land Use Change Permit process.
Section 7-102. Comprehensive Plan and Intergovernmental Agreements
The 2030 Garfield County Comprehensive Plan addresses mining in Chapter 3, Section 9 –
Mineral Extraction. It states that Garfield County has significant mineral resources that have,
and will continue to have, a considerable benefit to the economic health of the county. The
goals set in place want to make sure that mineral extraction is regulated appropriately and
promotes responsible development. The Future Land Use map from the Comprehensive Plan
illustrates the subject property as Residential Medium High (RMH). Scott goes into detail in
various reports and narratives as how the proposed mining operations will operate in
conformance with multiple regulatory agencies. Scott’s adherence to regulatory policies and
rules will result in limited, short term impacts to the surrounding properties while infusing
economic benefits, promoting a thriving community, and minimizing impacts to wildlife.
Section 7-103. Compatibility
The nature, scale, and intensity of the proposed gravel mining operation will be compatible
with adjacent land uses. The surrounding land uses are industrial and agricultural in nature
and there is an oil/gas pad to the west and agricultural uses to the north and east. Garfield
County is a “Right to Mine” County guaranteeing mineral rights owners the right to extract
minerals in all zone districts of the county. Visual and sound impacts will be mitigated with
Garfield County Conditions of Approval and DRMS Standards.
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Section 7-104. Source of Water
The project has a legal and adequate water supply plan. Mining of an aggregate deposit like
the Rifle Pit will involve affecting local groundwater and surface water. During active mining
operations, local dewatering efforts will pump groundwater to allow for aggregate mining.
During active mining, a perforated pipe will be buried three feet below the mining floor to
intercept additional groundwater, as needed during each mining phase. It is assumed that this
water will be collected in the dewatering pipeline and discharged to the Colorado River.
Water depletions will occur during mining operations from water lost with mined aggregate
and water used for dust suppression. On-site sourced water will not be used for potable water
demands. After mining is completed water depletions from the pit will be solely from
evaporation of the exposed groundwater in the finished gravel pit pond.
Augmentation of the exposed and captured groundwater is required per Colorado’s Revised
Statutes (CRS) to protect downstream senior water right holders and will be addressed by
Scott prior to subsurface mining.
Section 7-105. Central Water Distribution and Wastewater Systems
Scott is requesting a waiver from these standards. See Sections 2.8 and 2.9 of this application.
Section 7-106. Public Utilities
No additional public utilities are required for this project. There is an existing electric service
connection adjacent to the property along the I-70 N Frontage Road.
Section 7-107. Access and Roadways
The proposed mine will be accessed using the existing private driveway off the I-70 N
Frontage Road. The current access road will be improved by widening the driveway so trucks
and other machinery will be able to enter and exit from the property. The access road meets
or exceeds minimum County standards and comply with the CDOT standards too, for
adequate and safe access and will support projected Average Daily Traffic (ADT) at full build
out (Appendix B).
Section 7-108. Use of Land Subject to Natural Hazards
The subject property is not located within any known natural hazard areas.
Section 7-109. Fire Protection
Mr. Orrin Moon at the Colorado River Fire Rescue (CRFR) documented his input regarding
the Rifle Gravel Pit #1 project in his letters to Mr. Patrick Waller (July 27, 2020 and January
21, 2021). Copies of these letters are included in Appendix H. In summary, Mr. Moon
requested the following actions of Scott for this property:
“The Scott Contracting Rifle Gravel Pit #1 shall have a Garfield County assigned
address and the address numbers shall be posted at the entrance of the gravel
pit…CRFR is willing to work with Scott Contracting and Garfield County (to identify an
address)…”
In response to this comment, Scott will work with CRFR and Garfield County to assign an
address for the Rifle Pit #1 property.
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“Any open burning during clearing and grubbing of the gravel pit site and operation of
the gravel pit shall obtain Colorado River Fire Rescue Burn Permits and State of
Colorado Open Burning Permit. All pertinent permit requirements shall be followed
when burning.”
In response to this comment, Scott will obtain a CRFR Burn Permit and State of Colorado
Open Burning Permit, if needed.
It should also be noted that Scott will not allow materials or wastes to deposited in areas
susceptible to causing them to be transferred off the property.
Division 2 – General Resource Protection Standards
Section 7-201. Agricultural Lands
The proposed mine will not have a negative impact on agricultural lands or operations. There
is one tailwater channel of the Last Chance Ditch that runs across the property from east to
west and ultimately discharges into the Colorado River. Scott will not disturb the tailwater
channel in its existing location and implement Best Management Practices (BMPs) to prevent
mining operations from discharging into or comingling with these waters. Scott will install a
low-water crossing at the existing tailwater culvert crossing or collect the water in a pipe. The
Last Chance Ditch is located south of the property on the south side of I-70.
Section 7-202. Wildlife Habitat Areas
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 during mining operations, therefore some
wildlife may experience a slight change in traveled corridors to maneuver around the mine
area. Scott will work with the Colorado Parks and Wildlife and address any concerns they
have regarding area wildlife and animal habitat. Regarding preservation of native vegetation
Scott will reclaim the site and reseed with native vegetation recommended by the soil
conservation district that will be lost during operations. See Sheets C8 and C9 for a list of the
specific seeding and vegetation proposed for the Rifle Pit #1 area.
Mr. Kirk Oldham, Colorado Parks and Wildlife, provided comments in a letter dated August
28, 2020 regarding the Rifle Pit #1 project. Following is a summary of his comments:
“CPW recommends that all work equipment be sanitized and have any existing dirt,
vegetation, or seeds from landscaping and operation all work be removed before
leaving the work area.”
In response to this comment, Scott will practice proper equipment cleaning to minimize
transport of noxious weeds, dirt, vegetation, or seeds off-site.
“CPW recommends that measures be taken to avoid excessive sedimentation into the
Colorado River at the point of the operation.”
In response to this comment, Scott will apply for coverage under Permit No. COR400000,
CDPS General Permit (for) Stormwater Discharges Associated with Construction
Activity at least 10 days prior to the commencement of construction activities disturbing
greater than or equal to 1 acre. This permit requires installation of erosion and sediment
controls, including at the point of discharge of the dewatering pipeline to the Colorado River.
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This will reduce any impacts to the critical habitat for Threatened and Endangered species
downstream from the proposed operation. This permit has several requirements that address
water quality and stormwater management, including monitoring and reporting, and the
development and implementation of a Stormwater Management Plan (SWMP).
Scott will also apply for coverage under Permit No. COG603000 (Discharges Associated
with Subterranean Dewatering or Well Development) or Permit No. COG608000
(Discharges to Surface Water from Well Development and Pumping Test Activities) to
manage dewatered water. The specific permit will be determined once the water is sampled
and analyzed.
Coverage under a Nationwide Permit No. 7 will also be obtained for the outfall to the Colorado
River. Scott also submitted a Watershed Permit Application to the City of Rifle to address the
dewatering discharge within their Watershed Protection Area.
“CPW identified the area that the proposed project will be occurring in as Winter
Concentration Areas for both Mule Deer and elk. CPW recommends operational hours
take place between the hours of 7 a.m. and 5 p.m.”
In response to this comment Scott will limit winter operation hours between the hours of 7
a.m. and 5 p.m.
“Any new fencing needed for the proposed project should be constructed with wildlife
friendly fence.”
In response to this comment Scott will install wildlife friendly fence, if needed.
“The U.S. Fish and Wildlife Service should be consulted in regards to other Threatened
and Endangered plant and animal species which may be found at the site of the
proposed operation.”
In response to this comment Scott had SGM evaluate the potential impacts to seven Federally
listed plant species.
Seven federally listed species were evaluated for potential impacts resulting from this project,
per the USFWS Threatened and Endangered species list for the project area (IPaC,
September 2020). Based on this analysis, the USFWS identified the following species as
having potential to occur within the vicinity of the project:
Birds: yellow-billed cuckoo (Coccyzus americanus), Mexican spotted owl (Strix
occidentalis lucida)
Fishes: bonytail chub (Gila elegans), Colorado pikeminnow (Ptychocheilus lucius),
humpback chub (Gila cypha), razorback sucker (Xyrauchen texanus)
Flowering Plants: Debeque phacelia (Phacelia submutica), Ute ladies’-tresses orchid
(Spiranthes diluvialis)
Birds: The project area occurs within the range of the yellow-billed cuckoo; however, the
project would not impact any mature cottonwoods or riparian woodland habitats. The
conditions on the property are generally open pasture and wet meadow/emergent marsh,
which are not utilized by the cuckoo, and therefore no nesting or foraging habitat would be
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directly impacted. The Mexican spotted owl relies on deep shaded canyons, typically with
closed canopy forest: there is no habitat for this species in the project area or regional
surroundings.
Fishes: The Colorado River adjacent to and downstream of the project contains potentially
occupied habitat for the four endangered fish species, and designated Critical Habitat for the
pikeminnow and razorback sucker is located approximately 5 miles downstream at the Rifle
Bridge. The water depletions associated with the project have the potential to impact the four
fish species and would trigger consultation requirements with USFWS. There are temporary
depletions associated with the operation of the gravel pit, and there are permanent depletions
associated with evaporative losses from the reclamation pond. SGM is developing an
augmentation plan that would offset both temporary and permanent depletions from
authorized sources, and that would maintain the existing water conditions in the downstream
habitats.
Flowering Plants: Debeque phacelia is limited to arid badland exposures of Wasatch
formation; there is no such habitat within the project area or surrounding vicinity, and no
potential for this project to affect the phacelia. The project area does contain low-elevation
open wet meadows that constitute potential habitat for Ute ladies-tresses orchid. The nearest
known populations of the orchid are in the Roaring Fork Valley in the vicinity of the Iron Bridge
neighborhood of Glenwood Springs, approximately 30 miles upstream from the project.
Repeated surveys of suitable orchid habitat in the Colorado River valley have failed to locate
any orchid populations outside the Roaring Fork, therefore it is unlikely that the species would
occur on the project location. However according to the interim survey guidelines (USFWS,
1992) the portions of the property that consist of wet meadows that are not continuously
inundated and not dominated by cattails/bulrush/reedgrass do constitute potential habitat.
These areas of potential habitat are limited to the western portion of the property. There is no
suitable habitat within the initial development area of Stages 1-2 and the dewatering pipeline.
Orchid presence/absence surveys can only be conducted during the blooming season (late
July through August). Given the existing database of negative survey findings in the
surrounding area and the absence of habitat in the initial development areas, SGM proposes
to evaluate habitat suitability at a micro-site scale during the proposed quarterly wetland
monitoring. Areas that are identified as highly-suitable based on the USFWS interim
guidelines would be further evaluated during the blooming season for the presence of orchids.
No disturbance to suitable habitat would occur prior to such a habitat suitability analysis, in
concert with a formal orchid survey if warranted.
“CPW has concerns with the migration of unwanted predatory fish from the
recreational pond into the Colorado River and recommends a berm in between the
pond and the adjacent property be constructed.”
In response to this comment Scott will leave the construction perimeter berm in place along
the east, north, and western portions of the property for the reclaimed condition. Note the
height of the berm may change to achieve a balance for prohibiting fish passage on/off the
property and safe wildlife access. See the attached revised drawings, Appendix C, Sheet C8.
“CPW recommends additional seeding and planting of native brush species as well as
several cottonwood trees in any area disturbed by the proposed mining operation that
will not be turned into grazing pastures.”
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In response to this comment Scott will consider additional seeding and planting as
recommended, however received input and guidance from the Garfield County Vegetation
Manager. NRCS has also reviewed the proposed wetland and upland seed mixes and
application notes and provided approval with the proposed seed mixes (Stephen Jaouen via
email, 10/20/2020). See the attached Drawings (Sheet C8) which provide additional seeding
and planting details.
“The recreational pond should be constructed with bank slopes of 3H:1V ratios or
several escape ramps to allow for any wildlife to escape from pond.”
In response to this comment Scott has included a Typical Detail for the pond with a maximum
3:1 slope for the submerged portions of the pond (based upon the estimated groundwater
levels). See Sheet C8 in Appendix C.
Section 7-203. Protection of Waterbodies
The property currently has a tailwater channel of the Last Chance Ditch, which generally
bisects the property from east to west and discharges into the Colorado River. Scott will not
disturb the tailwater channel in its existing location and implement BMPs to prevent mining
operations from discharging into or comingling with these waters. Scott will install a low-water
crossing at the existing tailwater culvert crossing or collect the water in a pipe. The Last
Chance Ditch is located south of the property on the south side of I-70.
Scott will implement the following actions to support wetlands avoidance. The Drawings in
Appendix C depict the location of these improvements and modifications.
• Fence off the wetlands delineated on the Rifle Pit property and focus initial mining
operations in the areas (generally) east of these wetlands, at least 10 feet from the delineated
edge of the wetlands.
• Monitor the wetland condition and extent, and surface water conditions, throughout
the initial mining stages. Monitoring will use standard wetland delineation techniques in
compliance with Army Corps requirements.
• Monitor the current groundwater depth and the response to pit dewatering throughout
the initial mining stages, using professionally installed piezometers.
• Mine around and avoid the tailwater channel across the property through re-staging
the activities
Section 7-204. Drainage and Erosion
The existing topsoil will be stripped and used for the required 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. This berm will also mitigate noise produced during operation. These berms will serve
many purposes but for specific to drainage and erosion control they will prevent runoff of
stormwater and intercepted groundwater off site and protect the operations from the influence
and flooding by the Colorado River.
The mined area disturbed from the mining operations will be contoured so they can be
revegetated and will be revegetated to stabilize the surface from erosion. Section 2.12.8
addresses the temporary and permanent seeding activities and mixes to minimize erosion on
and off-site. This section also addresses the larger reclamation plans for the site.
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The site will have an 18.4-acre recreational pond and the remainder of the site will be graded
to compliment the surrounding topography and support revegetation. The external slopes will
be mined and graded at a 4:1 slope. Trees, shrubs, bushy-type vegetation and approved
grasses will be planted as approved by the NRCS and/or County.
When final landform is achieved, the surface will be stabilized by vegetation to reduce further
soil erosion from wind or water, provide forage and cover, prevent dust as required by State
Statute, and reduce visual impacts. A uniform vegetative cover will be established with an
individual plant density of at least 70% of pre-disturbance levels within 4 growing seasons per
Garfield County requirements. Noxious weeds will not be counted as part of the 70% cover.
The seed mixes in on Sheet C9 in Appendix C will be used to revegetate the site.
Section 7-205. Environmental Quality
The proposed gravel extraction operations will not cause the air quality to be reduced below
acceptable levels as established by the Colorado Air Pollution Control Division. There will be
no hazardous material stored or used at the proposed mine. Scott will apply for coverage
under an Air Pollutant Emissions Notice (APEN), if needed, upon approval of the project.
Based upon experience in similar operations at the Meeker, Colorado site, the first year of
operation will likely not require coverage, however, and will inform the APEN application for
following years of operation. An excerpt of the email from Mr. Christopher Reinhardt,
Environmental Protection Specialist from the Colorado Air Pollution Control Division, to Scott
confirming that the operations of the White River Pit near Meeker, Colorado, are below the
APEN reporting thresholds of 2 tons per year is included below.
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Section 7-206. Wildfire Hazards
The subject property falls within the Not Rated (NR) and Low Rating on the Garfield County
Wildland Fire Susceptibility Index Map.
Section 7-207. Natural and Geologic Hazards
The area proposed for mining operations is not a known natural or geologic hazard area.
Section 7-208. Reclamation
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 to meet Garfield County standards. Scott
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will start the reclamation process as soon as mining progresses throughout the site. After each
mining phase is completed, Scott will start backfilling pits with excess dirt and unused material.
The pits will not be filled in completely as part of the reclamation plan is to create a recreational
pond. The site will be graded to compliment the surrounding topography.
Area disturbed by grading will be contoured so they can be revegetated and will be
revegetated to stabilize the surface from erosion. Trees, shrubs, bushy-type vegetation and
approved grasses will be planted as approved by the NRCS and/or County.
Division 3 – Site Planning and Development Standards
Section 7-301. Compatible Design
The surrounding properties are primarily agricultural and industrial in use therefore should not
have any compatibility issues.
Section 7-302. Off-Street Parking and Loading Standards
There will be adequate on-site parking for mining and construction activity, within the property
owned by Scott.
Section 7-303. Landscape Standards
Where possible, Scott will work with the existing vegetation on the site, and if additional
landscaping materials are needed, the native vegetation found on site will be mimicked to
better ensure successful plantings.
Section 7-304. Lighting Standards
There will be no exterior lighting of the proposed facility.
Section 7-305. Snow Storage Standards
There will be adequate area for snow removal and storage within the property.
Section 7-306. Trail and Walkway Standards
Not applicable.
2.11 Floodplain Development Analysis
Scott understands that when a project is located within a Special Flood Hazard Area, if there
is an indication or suggestion that a project is located in a SFHA, or if a project is a division of
land or a PUD over 5 acres in size or proposes 50 lots or greater, the application must include
a Floodplain Analysis. A hydraulic model was developed using HEC-RAS to simulate flooding
effects during the 100-year flood event both before and after the proposed mining operation.
Hydraulic stresses were analyzed to determine appropriate erosion control and structural
characteristics of the earthen berm to withstand flood conditions. The difference between the
existing and proposed WSE was computed as the rise in the WSE. A summary of the model
WSE results is included in Appendix G.
2.12 Gravel Extraction Activities
Section 7-1002 of the LUDC requires the following information be addressed for Gravel
Extraction activities.
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Water Quantity and Quality Impacts/Floodplain Impacts
The Rifle Pit site will not store flammable or explosive solids or gases other than those required
to power the equipment and machinery. The site has been adequately designed to handle the
storage of flammable or explosive solids or gases and that the methods comply with the
national, State, and local fire codes and eliminate exposure to surface and ground waters.
This project will not allow materials or wastes to deposited in areas susceptible to causing
them to be transferred off the property.
Per the Floodplain Overlay Regulations and Development in 100-Year Floodplain
requirements included in Sections 3-301 and 4-109 of the LUDC, respectively, the site design
will prevent:
· Storage of fuel or hazardous materials including concrete/asphalt Batch Plants within
the Floodway, and:
· Includes a dewater/discharge plan that provides a detailed graphic representation of
how dewatering operations shall occur. This plan shall demonstrate that the discharge
will not exceed State standards for discharge into a water course or Wetland. Appendix
E includes a copy of a wetland report and dewatering plan.
Summary of Augmentation Plan for Dewatering Operations
To prevent injury to downstream water rights, the depletions from the Rifle Pit mining
operations will have to be replaced in time, amount, and location during times of a downstream
senior call. Some of this augmentation water can come from the dry-up of historically irrigated
fields that are removed from irrigation (dried) when the use of the property changes to gravel
mining. Whatever depletions are not covered by credits from the dry-up can be augmented
with water from a contract with the Colorado River Water Conservation District (River District)
or the West Divide Water Conservancy District (West Divide). Estimates of water demands
and augmentation supply are discussed in more detail in the August 6, 2019 SGM memo titled
Preliminary Water Resources Summary for Rifle Gravel Pit: Water Demands and
Augmentation Supply. A copy of this memo can be provided upon request.
During active mining operations, local dewatering efforts will pump groundwater from near the
Rifle Pit to allow for aggregate mining. Pumped water will likely be discharged into an onsite
drainage dewatering trench. Evaporation during active mining occurs from groundwater
exposed by dewatering, from the surface area of the dewatering trench(es). Water depletions
will also occur during mining operations from water lost with mined aggregate and water used
for dust suppression. After mining is completed and the pit can fill, water depletions from the
pit will be solely from evaporation of the exposed groundwater in the finished gravel pit pond.
Scott will file an application with water court for an augmentation plan decree to replace
depletions from the Rifle Pit operations (both during and after active mining operations). It can
take 1-3 years to go through the water court process and get a signed decree for an
augmentation plan, depending on negotiations with the Division of Water Resources and any
potential opposers. Therefore, Scott will also file an application for a Substitute Water Supply
Plan (SWSP) which will allow the gravel pit to operate without causing injury to other water
rights holders before a final decree is entered, with temporary approval from the State
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Engineer. An SWSP can only be approved for one year, but the applicant may request renewal
of the SWSP by repeating the application.
Air Quality
Scott understands that evidence needs to be submitted that that uses shall have current
CDPHE air pollution permits and shall meet emissions standards.
The proposed gravel extraction operations will not cause the air quality to be reduced below
acceptable levels as established by the Colorado Air Pollution Control Division. There will be
no hazardous material stored or used at the proposed mine. Scott will phase the mining
activities to be less than 100,000 tons during the first year of operations. Scott will size the
equipment requirements during this first year of operation and apply for coverage under an
APEN, if applicable.
Noise/Vibration
Scott understands that the LUDC, Division 7-1002 for Gravel Extraction, Section C.
Noise/Vibration, specifies noise thresholds per Neighboring Use (see Table 7-1002). The
property to the east has a Residential use and the noise threshold from 7 a.m. to 7 p.m. is 55
dB(A) and from 7 p.m. to 7 a.m. is 50 dB(A). Scott collected ambient noise levels1 on
September 30, 2020 between 12:38 p.m. and 12:45 p.m. at various locations to get the
ambient noise readings from the neighboring interstate. The modeling analysis was developed
to predict operational sound levels at adjacent properties and verify compliance of operations
with the Colorado Revised Statutes (CRS) 25-12-103 noise standards (Figure 6). The ambient
noise level measured at a location on the Rifle Pit #1 property approximately 100 feet from a
point on the north side of I-70 (Fence) was 55.7 dB(A). This level is equivalent (and slightly
greater) than the Residential use noise threshold for the 7 a.m. to 7 p.m. timeframe.
Scott also took noise measurements from one of their existing operations that would reflect
the proposed operations and equipment for the Rifle Pit #1 (Figure 7). The projected noise
level at the Residential property boundary would be about 70.8 dB(A) assuming the equipment
is placed 200 feet inside the boundary. This projected noise level doesn’t account for the
equipment being on the floor of the pit, approximately 30 feet below the existing grade, nor
does it include the impact of the perimeter berms to provide noise mitigation.
The net effect of the Scott Rifle Pit #1 operations only is expected to be below the 50 dB(A)
threshold for neighboring Residential use. Scott could measure noise levels upon
commencement of mining operations; however, with the ambient noise levels of I-70, they
would not be representative. Table 3 summarizes Scott’s noise data.
1 Ambient Noise (per LUDC definition). The total of all noise in a situation, independent of the projected noise from any
new particular source or increase in existing sources of noise. Ambient noise includes both sustained background readings
and existing fluctuations in noise levels.
IHC Scott – Rifle Gravel Pit #1 March 2021 2-17 Figure 6. Ambient Noise Measurements at Rifle Pit #1 Property on September 30, 2020.
IHC Scott – Rifle Gravel Pit #1 March 2021 2-18 Figure 7. Noise Measurements from the Meeker, Colorado Scott Operations
IHC Scott – Rifle Gravel Pit #1 March 2021
2-19
Table 3. Sound Monitoring Data
Sound Monitoring
SCI-001 Sand & Gravel Operations
Meeker, Colorado
Distance from
Active Mining
Operations
Measured Noise Level
(dBA)
Ambient Noise
Measurement Location
Measured Ambient Noise
Level (dBA)
25 ft. 85.7
50 ft. 82.5
75 ft. 79.1
100 ft. 77.8
125 ft. 76.3
150 ft 75.3
175 ft. 74
200 ft. 70.8 CDOT Fence (Fence
between CR 346 and I-70) 71.2
225 ft. 69.9 Centerline of CR 346 69.8
250 ft. 68.5
275 ft. 67.9
300 ft. 66.8
325 ft. 66.3
350 ft. 65.7
375 ft. 65.5 SCI Property Line 60.7
400 ft. 63.9 100-ft inside SCI’s
Property Line 55.7
(Source: Noise Monitoring was performed with a calibrated 3M™ SD-200 Sound Detector by Daniel Spahn, Sr.
Safety Manager for Scott Contracting Inc.)
This noise monitoring session shows that hearing protection should be worn whenever
anyone is 40 feet or closer to any processing equipment in use at the pit.
Visual Mitigation
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.
County Road System
The I-70 N Frontage Road (also known as CR 346) will be used to access the site (Figure 1).
Copies of the CDOT-approved Traffic Impact Study and CDOT Notice-to-Proceed are
included Appendix B. Scott understands that any required improvements shall either be in
place prior to or constructed in conjunction with the proposed use/site.
IHC Scott – Rifle Gravel Pit #1 March 2021
2-20
Compatibility with Surrounding Land Uses
The nature, scale, and intensity of the proposed gravel mining operation will be compatible
with adjacent land uses. The surrounding land uses are industrial and agricultural in nature
as there is an oil/gas pad to the west and agricultural uses to the north and east properties.
Revegetation / Reclamation
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 to meet Garfield County standards. Scott
will start the reclamation process as soon as mining progresses throughout the site. After each
mining phase is completed, Scott will start backfilling pits with excess dirt and unused material.
The pits will not be filled in completely as part of the reclamation plan is to create a recreational
pond. See Figure 8 for proposed pond location and proposed future mineral mining
operations. The site will be graded to compliment the surrounding topography, and slopes will
be mined and graded.
Area disturbed by grading will be contoured so they can be revegetated and will be
revegetated to stabilize the surface from erosion. Trees, shrubs, bushy-type vegetation and
approved grasses will be planted as approved by the NRCS and/or County.
Description and Types of Reclamation
Scott will achieve the required reclamation of the affected land per the Garfield County Land
Use Permitting and seeding regulations using existing and available equipment. The primary
reason for this goal is to minimize dust and erosion of the property and restore the site back
to its natural conditions to the extent practicable.
Sheet C8, Reclamation Plan in Appendix C (Figure 8) depicts the amount of acreage proposed
for each reclamation activity. All reclamation will occur with specified equipment and methods
for attaining successful revegetation of the property. It is assumed that an 18.4-acre pond will
be present post-mining.
Post-Mining Land Use
The adjacent properties are primarily agricultural, county and interstate roadways, oil and gas
well pad and the Colorado River. The post-mining land uses will be like the current land use
and not conflict with adjacent land uses, which are currently comprised of agricultural uses.
IHC Scott – Rifle Gravel Pit #1 March 2021 2-21 Figure 8. Reclamation Plan
IHC Scott – Rifle Gravel Pit #1 March 2021
2-22
Implementation of the Reclamation Plan
Topsoil Segregation, Preservation, and Replacement
The topsoil excavated, stockpiled and or used for berm construction during Phase 1 will be
used to support the revegetation of the site.
Backfilling and recontouring of the site will occur after the mining and extraction activities
finish. Pit slopes will generally be backfilled with subsoils, overburden, and unmined materials.
This will be placed with a bulldozer and haul trucks. Then the use for a roller for compaction
and sloping will be tracked in. Recontouring to a rough texture will support the establishment
of broadcasted seeds and moisture retention. Stored topsoil and growth medium will be
replaced evenly to a depth of 4-6 inches unless site conditions preclude this depth. Topsoil
will also be left very rough. Soils will not be worked when wet to avoid mixing, loss of topsoil,
and potential erosion issues.
Final Grading
Final grading of the site is depicted on the Reclamation Map in Appendix C, Sheet C8 (Figure
8). This figure shows the anticipated maximum slope gradient range for reclamation. The site
will need to take on fill dirt for a source of a disposal area for clean dirt and to fill part of the
pit, minimizing the size of the pond and reducing evaporation potential.
The creation of a pond is planned for the site. Existing ephemeral draws and washes passing
through the mine area will be reestablished or allowed to continue conveyance of ephemeral
flows through the site.
Seeding
There are different types of seed mixes to support temporary and permanent stabilization and
reclamation of the site. Sheet C8 includes and estimate of the revegetation areas by site
feature.
Temporary Seed Mix
Final seeding is best done in the late fall; therefore, if construction occurs in the summer, it
may be desirable to apply a temporary seed mix to the area to help minimize erosion and
provide some site stabilization. Temporary seed mixes are relatively inexpensive, and the
large seeds germinate quickly.
Long-Term/Permanent Seed Mix
Seeding should occur in the late fall to avoid seeds from germinating in the summer or early
fall, and then either desiccating or freezing. Drill seeding could be utilized on more level
terrain, but broadcast seeding will likely be needed on steeper slopes. Drill seeding will be
the preferred method where equipment access is feasible; seed will be placed in direct contact
with the soil at an average depth of 0.5 inch. For drill seeding applications, small seeds shall
be packaged separately to allow for separate application. The drill seeding rate is 18 lbs per
acre and the broadcast seeding rate is 25 lbs per acre.
IHC Scott – Rifle Gravel Pit #1 March 2021
2-23
Broadcast seeding will be employed in areas where drill seeding is not possible. Seed will be
uniformly applied over the disturbed areas with manually operated cyclone-bucket spreaders
or mechanical spreaders. Table 1 and Table 2 on Sheet C9 (Appendix C) provides detail
regarding the type of seed mix, form, and application rate.
Fertilization
The proposed grass mixes will require little to no fertilization.
Revegetation
When final landform is achieved, the surface will be stabilized by vegetation to reduce further
soil erosion from wind or water, provide forage and cover, prevent dust as required by State
Statute, and reduce visual impacts. A uniform vegetative cover will be established with an
individual plant density of at least 70% of pre-disturbance levels within 4 growing seasons per
Garfield County requirements. Noxious weeds will not be counted as part of the 70% cover.
Table 1 and Table 2 on Sheet C9 (Appendix C) provides detail regarding the type of seed mix,
form, and application rate.
Topsoiling
Topsoil will be stockpiled, and later placed on disturbed areas. The anticipated range of depths
for those areas where topsoil will be replaced will be 4 to 6 inches.
Revegetation Success Criteria
Revegetation will be deemed adequate when erosion is controlled, and vegetation is
approximately 70 percent of surrounding undisturbed vegetation profiles and is considered
satisfactory according to DRMS standards. State or county-listed noxious weeds, as well as
alien annual invasive species do not count as part of the 70 percent cover.
Noxious Weed Control
Noxious weeds identified through the Colorado Noxious Weed Act (CRS 35-5.5) will be
controlled per state and county regulation. Control will be achieved by:
· A weed survey of the permit area will be completed every spring.
o A copy of the existing conditions Noxious Weed Survey is included in Appendix
F.
· Infestations will be treated using approved chemicals and will be sprayed by the
landowner or a certified applicator.
· After reclamation, weed surveys and treatment will continue until the perennial cover
and production of the site have met DRMS requirements and bond release has been
obtained.
Mr. Steve Anthony, Garfield County Vegetation Manager, provided the following comments
regarding the project:
“The Weed Management Plan needs to provide more details on noxious weed
management during mining activities.”
IHC Scott – Rifle Gravel Pit #1 March 2021
2-24
In response to this comment Scott has updated the Weed Management Plan to include
language that addresses the treatment of all noxious weeds on a biannual basis, with an
herbicide application in the spring (late May) and late summer (late August). Gravel storage
piles will also be treated with a bare ground herbicide if the piles are expected to remain for
more than one season. Scott will use a Colorado-certified herbicide applicator. All work
equipment will be sanitized and have any existing dirt, vegetation, or seeds from landscaping
and operational work removed before leaving the work area. Prior to bond release, Scott will
conduct a noxious weed inventory and bond release reports developed by third parties for
submittal to DRMS and Garfield County.
“Weed Management Plan should include a timetable for Russian-olive and tamarisk
removal for non-reclaimed areas.”
In response to this comment Scott will include a timetable for Russian-olive and tamarisk
removal for non-reclaimed areas as part of their Weed Management Plan, if needed.
Reclamation Plan Schedule
The reclamation seeding plans will occur by mining phase and comply with the County and
CDOT standards for application rates. Table 1 and Table 2 on Sheet C9 (Appendix C)
provides detail regarding the type of seed mix, form, and application rate.
Previously Disturbed/Unnecessary Areas
Reclamation of unnecessary mine components (e.g., previously used areas which no longer
will provide productive aggregate extraction) will be reclaimed in the first year from receipt of
permit. This process is anticipated to take a year for grading and topsoil redistribution, and
several years for appropriate reclamation species establishment and weed control.
Active Mining Areas
Reclamation of the southeast pod occur immediately upon cessation of material extraction.
Given these areas may be active for several months, reclamation may not begin for quite
some time. Reclamation of these areas may take up to a year for regrading, contouring and
reseeding, and multiple years after that to establish reclamation species and control noxious
weeds.
Monitoring Reclamation Success
Continued monitoring of the reclamation will ensure its success. The operator plans to use
the local NRCS office and Garfield County to determine the capacity of the reclaimed land to
control erosion. If minor changes or modifications are needed to the seeding and reclamation
plan, revision plans will be submitted to the County. It is hoped that the County will aid in
evaluating the success of the ongoing reclamation process. Information on all disturbed and
reclaimed areas, as well as any other important items regarding the reclamation, will be
submitted in the annual reports to the County and CPW, will also be consulted on the progress
of reclamation.
IHC Scott – Rifle Gravel Pit #1 March 2021
2-25
Enforcement
Scott acknowledges the enforcement requirements listed in the LUDC and that the County
has performance standards in place that could lead to revocation of the Land Use Change
Permit if continued violations of the permit occur over a period of time.
IHC Scott – Rifle Gravel Pit #1 March 2021
3-1
3.0 Referral Agency Coordination
Scott communicated with the following agencies as part of this application:
Colorado Department of Transportation
Colorado Division of Reclamation Mining and Safety
Colorado Parks and Wildlife
Colorado River Fire Rescue (Station 41)
Division of Water Resources
Garfield County Designated Engineer
Garfield County Environmental Health (Air)
Garfield County Vegetation Management
City of Rifle
Town of Silt
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix A
Appendix A
Forms
Payment Agreement Form
Proof of Ownership (title work, copy of deed)
Statement of Authority Form
Names and Mailing Addresses (properties within 200 feet)
Mineral Rights Ownership
Pre-Application Summary
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix B
Appendix B
Traffic Study
Access Permit
Notice-to-Proceed
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix C
Appendix C
Drawings
Boring Logs
Dewatering Pumping Report
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix D
Appendix D
Grading and Drainage Plan
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix E
Appendix E
Impact Analysis
Wetlands Memo & Dewatering Plan
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix F
Appendix F
Noxious Weed Survey
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix G
Appendix G
Floodplain Development Analyses
IHC Scott – Rifle Gravel Pit #1 March 2021
Garfield County Special Use Permit Application Appendix H
Appendix H
Referral Agency Letters