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2021-03-16_PERMIT FILE - M2021016
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2021-03-16_PERMIT FILE - M2021016
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Last modified
12/28/2024 7:45:41 AM
Creation date
3/17/2021 7:15:39 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2021016
IBM Index Class Name
PERMIT FILE
Doc Date
3/16/2021
Doc Name
Objection
From
Schumaker & O'Loughlin, LLC
To
DRMS
Email Name
DMC
THM
Media Type
D
Archive
No
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copies of those materials which is evidence that the Application is not appropriately completed. The <br /> Mineral Rules and Regulations for Construction Materials gives the Board discretion to deny an <br /> application if all application materials required by C.R.S. § 34-32.5-111(2)(b)(I)-(IX) are not provided.See <br /> Mineral Rules and Regulations for Construction Materials at 1.4(8). <br /> Additionally,the Aggrieved Parties are concerned that the proposed reclamation of the Blue <br /> Creek Project does not meet the standards of the Colorado Land Reclamation Act for the Extraction of <br /> Construction Materials. <br /> Request for the Board to not Consider the Application at this Time. <br /> The Mineral Rules and Regulations for Construction Materials 1.4(4) requires proof of the <br /> required notice before the Board can consider an application.As noted above, Notice was not complete <br /> as required because it was missing the entire application.As such,the Board cannot consider the <br /> Application at this time. <br /> Request for Inspection of Documents. <br /> If the Board does not deny the Application at this time and continues in its consideration of the <br /> Application, the Aggrieved Parties request inspection of all applications, public notices, inspection <br /> reports, documents, maps, exhibits, correspondence,tests, analyses, records of actions or findings of <br /> the Board or Office pursuant to the Mineral Rules and Regulations for Construction Materials Rule <br /> Petition for Hearing Pursuant to C.R.S. §34-32.5-114 <br /> C.R.S. § 34-32.5-114 gives an aggrieved person the right to object to a project and petition for a <br /> hearing.The Aggrieved Parties are aggrieved persons within the meaning of C.R.S. § 34-32.5-103(1.5) <br /> and Rule 1.1(4) as they will suffer actual loss or injury to their aesthetic interests, potential loss or injury <br /> to their economic interests, as well as adverse health impacts from dust.As such,they object to the Blue <br /> Creek Project and submit this petition for a hearing to determine if the application should be approved <br /> or denied, if there was a complete application submitted, if the notice requirements have been met, <br /> what actual and potential injury or loss will result from the Blue Creek Project, and all supporting <br /> documents for noise, light, dust, and truck traffic, as well as economic impacts on property value. In the <br /> absence of a hearing, the Aggrieved Parties will immediately appeal the Office or Board's decision <br /> pursuant to Rule 1.4.11, and will follow that up with legal action if necessary. <br /> Sincerely, <br /> Chris Mochulsky <br /> Attorney for George and Christina Sterner, David and Teresa Yaklin, and Matt Delany <br /> 3 <br />
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