2016-05-20_GENERAL DOCUMENTS - C1981035

• Permit No: C1981035
• IBM Index Class Name: General Documents
• Doc Date: 5/20/2016
• Doc Name: Citizen Complaint Federal Permit No. CO-0106A
• From: Wild Earth Guardians
• To: OSM
• Permit Index Doc Type: General Correspondence
• Email Name: DIH
• Email Name: RAR
• Media Type: D
• Archive: No

To mitigate for this and provide for the safety of the traveling public, residents, and mine traffic, the route
proposed for use by haul trucks needs to be improved to minimum county standards. Per LPLUC 74-
91(c), design standards for such projects dictate:
1. Roads carrying 80-999 ADT (40 to 499 one-way trips) Local, 10 plus units require a surface width
of 24 feet plus 3 -foot shoulders (total 30 feet) and have 60 feet of Right of Way
2. Roads with more than 400 ADT (200 one-way trips) need to be paved
3. Site distance must be provided and designed at all driveways and intersections as prescribed
4. Horizontal alignment must be provided as prescribed
With respect to traffic safety, the project would only be compatible upon completion of all required
improvements identified in the previously mentioned draft RIA.
As previously stated, typically projects complete all public improvements prior to commencing use.
Within the draft RIA, a schedule was developed for recommendation which would allow operations to
continue as the road improvements were "phased" over time; contemplating reduced truck hauling
allowances until the improvements would be completely implemented. Please see Table 7 for the scaled,
phased development considerations for recommendation.
Background and GCC's Proposal
Through approximately 2010, GCC haul trucks traveled to both the north and the south. The north route is
the 6.4 mile segment that is the subject of this permit review as GCC has self-selected this route despite the
availability of other possible options. There are two routes to the south — one which takes north CR 120 to
meet SH 140 near Breen and the other which takes south CR 116 to CR 119 to meet SH 140 near Kline.
In 2010, accident reports identify the potential for both ends of CR 120 to become blocked, which
produced the local fire district (Fort Lewis Mesa) expressing concern with such potential relative to heavy
traffic/loading upon both the north and south routes. This brought the overall increase of truck hauling
transport to the County's attention, and led to the County notifying GCC of the need for a land use permit.
As part of a land use permit, GCC would need to improve any roads and intersections it used to county
standards. When GCC submitted their land use application in 2012, it had identified north CR 120 as its
designated route. Table 5 shows the scale of improvements that would be needed with the various
transport options.
Table S. Scale of Roadway Improvements for Three Transport Options
Transport Route
Approx. Miles of
Roadway
County Road
Intersections
State Highway
Intersections
Driveways
(Site Distance)
CR 120 N
7
0
1
20
CR 120 or119S
7-9
5
1
70
Loop Route
14-16
5
2
90
As the applicant chose the 6.4 mile segment of north CR 120 for their designated route,
extensive/compounded impacts to this section of roadway occurred primarily due to (1) rerouting of traffic
that had formerly gone to the south now going to the north and (2) increased production. Table 6 shows
how traffic patterns shifted as GCC increased its production and rerouted its traffic.
Project No. 2012-0089 PC
4852-5627-2942, v. 3
Page 17 of 32
(DM, VS, DP)