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2024-07-16_REVISION - M1986123 (3)
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2024-07-16_REVISION - M1986123 (3)
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Last modified
7/16/2024 9:47:55 AM
Creation date
7/16/2024 9:29:37 AM
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Template:
DRMS Permit Index
Permit No
M1986123
IBM Index Class Name
Revision
Doc Date
7/16/2024
Doc Name
Objection
From
James G. Zack, Jr.
To
DRMS
Type & Sequence
AM1
Email Name
JPL
JLE
Media Type
D
Archive
No
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the Stroh Pit operation Coulson is asking the Division to allow this without the owner's <br /> permission. Coulson is now claiming that they need the Stroh Pit overburden to reclaim <br /> the Kirtwright Pit, notwithstanding the fact that Coulson owns other nearby gravel <br /> operations. I also note that, if this amendment is approved, Coulson claims it will take <br /> seven more years to complete the Kirtwright Pit reclamation, which is coincidently, the <br /> same amount of time given to Coulson to mine and reclaim the Stroh Pit. <br /> I have also been given to understand that Coulson's operations have violated code in <br /> several respects, particularly they have been operating beyond the Kirtwright Pit permit <br /> boundaries. Of particular concern is the damage done to Ms. O'Brien's property and the <br /> unwillingness of Coulson to repair the damage and finish the required reclamation. Even <br /> though the Department has notified Coulson of issues such as this and apprised Coulson <br /> of necessary corrective actions that need to be taken,Coulson apparently does not comply <br /> fully, or ignores the notices from the Department with little or no consequences. <br /> Ultimately, I have been advised, the Department bends to Coulson's wishes. By way of <br /> example,Coulson violated the original Kirtwright permit boundary and simply asked for <br /> an amendment after the fact to extend the boundary of the permit. Failure to reclaim the <br /> Kirtwright properties for 16 years after mining was completed and the apparent inability <br /> of the Department to hold Coulson accountable give me reason to question whether <br /> Coulson will follow the conditions included in the County's USR permit for the Stroh Pit. <br /> And,since there is no guaranteed time frame to finish mining how long will the residents <br /> of Thompson River Ranch have to wait for the required reclamation?Will it be the 7 years <br /> in the County's permit or 16 years like the Kirtwright Pit has taken? <br /> There is also concern regarding the water augmentation plan for the Kirtwright Pt which <br /> is evident in many of the inspection reports by various agencies. This should lead the <br /> Department to question the accuracy of Coulson's claims concerning water rights for the <br /> Stroh Pit. <br /> Using the Kirtwright Pit as a current example,Coulson has not successfully demonstrated <br /> that they can operate within the requirements and conditions set by the Department and <br /> Larimer County,or within the timeframe they claim in the pending application.With this <br /> new amendment, the Kirtwright Pit will not be reclaimed for some 23 years after mining <br /> has been completed. Note, please, that the proposed completion date in this application <br /> is now May 2031. While the Department calls this a reclamation permit, what Coulson is <br /> proposing is anything but reclamation. <br /> My objection to this Kirtwright Pit amendment is that it appears to be nothing more than <br /> a long line of excuses and passes given to Coulson to continue to extend operations for <br /> their benefit. A company that has been doing this type of work for several generations <br /> should know the regulations governing this work and the requirements for completing <br /> such an undertaking before they start work on a large scale landscape altering endeavor <br /> 2 <br />
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