2016-08-02_PERMIT FILE - M2016009 (3)

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August 2, 2016 Division of Reclamation Mining and Safety RECEIVED 1313 Sherman Street, Room 215 Denver, CO 80203 AUG 0 2 2016 RE: Opposition Letter—Permit Number M2016009 DIVMINNGANDS OF SAFETY RECLAMATION PP MINWG AND SAFETY To Whom It May Concern: Pueblo County zoning districts A-1 and A-2 are "designed to retain and promote the appropriate use of dry range and irrigated lands and encourage open use of the land in keeping with its natural characteristics and agricultural functions." Fremont Paving and Redi-Mix Inc.'s application for a construction materials operation reclamation permit for a surface mine on 44' Lane in Pueblo County, Colorado—previous versions of which have been denied on two separate occasions—is inconsistent with this purpose. The proposal substantially modifies the land use plan, creates discordant activities across surrounding properties and communities, and potentially poses threats to the public health, safety, and welfare of the region's citizens—conditions not supported by Pueblo County Code 17.140.050 Special Use Permit Standards. My opposition is based upon more than a decade of land use and economic planning engagements in Pueblo County—first as staff at the Office of Economic Development and International Trade during the Owens administration;then for seven years as the Executive Director of the Palmer Land Trust, which during my tenure produced Our Land, Our Water, Our Future:A Conservation Plan for the Western Lower Arkansas Valley(developed with support from a broad group of Pueblo County stakeholders, including county commissioners,the plan identifies agricultural and natural Land conservation priorities in Pueblo County, of which these lands are a part);then as the Lincoln Loeb Fellow at Harvard University's Graduate School of Design and the Lincoln Institute of Land Policy, a land-use and taxation policy foundation; and,finally,as the owner and principal of Innovative Conservation Solutions, LLC,which is engaged in Land use planning activities in the immediate vicinity of the proposed surface mine. The economic impact of agriculture in Pueblo County is significant: crop and livestock sales in 2012 were $51,091,000 according to the U.S. Census of Agriculture. Redi-Mix Inc.'s application fails to examine the true costs of heavy industrial activity to farmers, county government,and the regional agricultural economy, of which the Bessemer Ditch and the Lands surrounding it are the epicenter. Agricultural land conversion, especially at this scale,frequently precipitates other forms of land conversion, exit from the marketplace by producers, and a decline in agricultural jobs, revenue,and related industries. It disincentivizes new agricultural investments in the region. Reclamation activities, especially the reestablishment of grasslands at the end of the project, have a high Planning-, , ., Designr,, :•M. .,. ,.,, Collaborations. I Fundraising•,,.,,,_