Memorandum

To: Gary Harrison, Danielle Wiebers, Matt ErichsenFrom: Kiowa Engineering/Liz KleinDate: September 12, 2018Project: Pete Lien & Sons Trans Colorado Concrete Judge Orr Road Ready Mix Concrete PlantSubject: Wetland Avoidance Area

Following our field meeting of Sept. 5, 2018 at the project site, I have established a wetland avoidance area on the 92 +/- acre site on Judge Orr Road to be used for planning purposes relative to the 22.6 acre concrete plant footprint. Prior to our field visit, I had referred to published resources for background information that may indicate potential jurisdictional wetlands. First, the USGS Falcon Quadrangle depicted two “blue line” drainageways in the northeast and southwest corners. These “blue lines” are the first prompt for the USACE for jurisdictional Waters of the U.S. The drainageway in the southeast appears to have been improved in recent years and may or may not be Waters of the U.S. The drainageway in the northeast corner likely is a jurisdictional waterway as it appears to be a wetland channel. As such, any adjacent wetlands would be jurisdictional.I then referred to the NRCS Custom Soil Resource Report for El Paso County Area, Judge Orr Road. A large body of hydric soil, #29 Fluvaquentic Haplaquolls, is located in the easterly portion of the site. This soil is listed as having a depth to water table of 0-24 inches. These characteristics strongly indicate potential wetlands. During our site visit, the area of the potential wetlands had a different plant composition. The upland portions of the site are blue grama grass dominant. A large portion of the upland plant community is composed of weedy herbaceous species such as kochia, Russian thistle, descurania, tumble mustard, horseweed, and goosefoot. The weedy species are likely due to overgrazing and animal concentration. In general, the existing vegetation cover appears sparse due to drought conditions during the previous winter and spring that endured until almost August 1, 2018.The wetland areas had plant communities composed of rush, sedges, softstem bulrush, cattails, persicaria, mints, and coyote willow, typical of sub-irrigated meadows of the high plains ecozone. With these factors indicating wetlands, the NRCS Soils Map, National Wetland Inventory Map and aerial photographs were used to develop the avoidance line as placed on the Site Survey. Within the Avoidance Area of the site as shown on attached Figure 1, there are intermingled areas of uplands. A detailed Wetland Delineation would need to be generated and submitted to the USACE for Concurrence for projects in this area. To sum up the significance of the Avoidance Area, if the concrete plant footprint is sited outside of the Avoidance Area, consultation and permitting with the USACE will not be necessary. It is also recommended that a geotechnical investigation should be arranged to determine site suitability regarding the high water table and the plant operations.

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