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2016-04-19_PERMIT FILE - M2016010 (32)
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2016-04-19_PERMIT FILE - M2016010 (32)
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Last modified
5/24/2021 10:36:46 AM
Creation date
4/19/2016 6:19:44 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2016010
IBM Index Class Name
Permit File
Doc Date
4/19/2016
Doc Name
Letter of Opposition
From
Milliken Weiner Berg & Jolivet PC
To
DRMS
Email Name
AME
Media Type
D
Archive
No
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Mulliken Weiner Berg & Jolivet P.C. <br /> Attorneys at Law <br /> RECEIVED <br /> Steven K. Mulliken Alamo Corporate Center Joe D. Kinlaw II <br /> Murray . Weiner Emory G. Allen <br /> l y l 102 South Tejon Street, Suite 900 <br /> Caro een F.Jo ivet Colorado Springs, Colorado 80903-2238 APR 19 2016 Paul G. Kloster' <br /> Karl A. Berg, Jr. <br /> Trevor J. Young Telephone (719) 635-8750 DIVISION OF RECLAMATION Of Counsel: <br /> Facsimile (719) 635-8706 MINING&SAFETYJanet K. Williams <br /> www.mullikenlaw.com <br /> Ad Witted i,,Ma yl—d <br /> mulliken C>mullikenlaw.c o m <br /> April 18, 2016 <br /> VIA FEDERAL EXPRESS <br /> Ms. Amy Eschberger <br /> Mr. Wally Erickson <br /> Colorado Division of Reclamation, <br /> Mining and Safety <br /> 1313 Sherman Street, Room 215 <br /> Denver, Colorado 80203 <br /> Re: Hitch Rack Ranch Quarry Permit Application; Application Number M-2016-010 <br /> Dear Ms. Eschberger and Mr. Erickson: <br /> Samuel K. Wells and I currently serve as Co-Trustees of the Amended and Restated Trust <br /> Agreement of the Harold C. Ingersoll Revocable Trust dated August 11, 2008 (the "Trust"). <br /> Harold (Buck) Ingersoll prior to his death owned a 300-acre ranch off Highway 115 which is <br /> adjacent to the land which is proposed to be mined under the Construction Materials Regular <br /> (112) Operation Reclamation Permit Application dated February 17, 2016 (the "Application") <br /> submitted by Transit Mix Concrete Co. ("Transit Mix"). The Trust currently owns the Ingersoll <br /> Ranch, and this letter is to notify you of the Trust's opposition and objection to the Application <br /> and to respectfully request that the Application be denied. The Trust is an "aggrieved person" <br /> under C.R.S. § 34-32.5-114 entitled to file a written objection to the Application because its <br /> property risks injury and loss to its aesthetic and conservational interests as a result of the <br /> Application. See C.R.S. § 34-32.5-103(1.5). Some of our reasons for opposing the Application <br /> are set forth below. <br /> Destruction of the Unique Environment <br /> We have relatively recently been advised of the Application. The area on which the <br /> mining is proposed is very special land which is deserving to be preserved and not mined, as an <br /> exception to our normal state priorities. The proposed site is a part of the Aiken Canyon <br /> Potential Conservation Area and was identified by the Colorado Natural Heritage Program in <br />
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