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- Fluctuations in human population and correlated demand across diverse <br />economies (agriculture, urban, commercial, industrial) and relative to local and <br />regional commercial availability of product. <br />- A Life of the Mine permit exists to accommodate diverse unpredictable natural <br />and socio- economic fluctuations in order to assure a continuous supply of <br />construction materials to meet the vital local, regional, and state transportation <br />and infrastructure needs of Colorado. DRMS seeks to exert exceptional control <br />over the marketplace by managing stockpile sizes. This is inappropriate. <br />Through artful use of the language, the Office will transform saleable products <br />into a liability, or waste, forcing an operator to change their deliberate strategies <br />of marketing and selling a product thereby having a direct negative effect on the <br />marketplace. <br />e) The sand stockpile was estimated to be 515,555 cubic yards in volume by the Division <br />based on inspection observations and aerial photography of the site. <br />i. The key word is `sand' stockpile. This stockpile is a `product' stockpile. It <br />becomes `product' after considerable risk, investment, and expense, as follows: <br />- The location of the site must be found and available for purchase within a place <br />where commercially viable aggregate reserves exist. The considerations that <br />restrict viability or otherwise serve to limit access to the deposit would <br />considerably lengthen this reply. <br />- Even when drilling the location for viability, the actual depth, extent, and <br />percent recovery by product cannot be assured in advance. <br />- The location must be financially secured as an investment, with all attending <br />risk and costs (e.g., interest paid on a note) of an investment, until all <br />necessary Federal, State, County, and related permits are obtained. This takes <br />substantial initial capital, and increasingly so. <br />- Other expenses, many too numerous to list, include Capital investment in <br />personnel, specialists in diverse fields, staffing and equipment, are <br />unavoidable expenditures made often years before the venture begins to return <br />any of the original investment capital. <br />- Once operational, the deposit must be removed, transported, sorted and <br />manufactured by processing into diverse commercially viable product for an <br />unknown variable demand that only reveals itself over a span of time. Time, <br />and lots of it, is essential to recapture the initial lost capital. Again and again, <br />it's why these are `life of the mine' permits. <br />- This permit identifies many of the diverse products that may be processed or <br />otherwise made available for the continued economic viability of the local <br />area it serves. <br />Sand is, therefore, a commercially viable and essential product created at <br />considerable expense and which has an established commercial value. We assert <br />that the sand stockpile is an asset under any circumstance. <br />So let's examine the meaning of the word asset, juxtaposed with the meaning of <br />the word liability. <br />Varra Companies, Inc. correspondence of 30 March 2015 to the Colorado Office of Mined Land Reclamation in 7 <br />reply to the OMLR Inspection Report of 28 August 2014 — Kurtz Project — M -1999 -006 <br />