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2024-08-05_REVISION - M1986123 (4)
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2024-08-05_REVISION - M1986123 (4)
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Last modified
1/16/2025 6:59:13 AM
Creation date
8/5/2024 2:26:45 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1986123
IBM Index Class Name
Revision
Doc Date
8/5/2024
Doc Name
Objection
From
Witwer,Oldenbug,Barry & Groom, LLP
To
DRMS
Type & Sequence
AM1
Email Name
JPL
JLE
Media Type
D
Archive
No
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d) Traffic/Roads <br /> Access to the Property is via the I-25 Frontage Road("Frontage Road'), which abuts the <br /> Kirtright Property. From the Kirtright Property, Coulson will travel east to access the Property <br /> and mine the Cells. Area residents expressed concern that an increase in trucks and equipment <br /> entering and exiting the Frontage Road will create an unsafe roadway and thus, be incompatible <br /> with the surrounding area. <br /> Coulson hired LSC Transportation Consultants, Inc. to conduct a traffic impact analysis <br /> of the Project on the Frontage Road. LSC's complete report("LSC's Report") is attached to this <br /> Letter as Exhibit E. LSC's Report concluded that the Project will not change the current and <br /> projected Levels of Service on the Frontage Road. <br /> After considering the results of LSC's Report, however, Coulson proactively decided to <br /> change the truck route during peak traffic hours to further accommodate the existing traffic <br /> patterns on the Frontage Road. Specifically, during peak morning and evening traffic hours, <br /> Coulson's trucks will primarily enter the Kirtright Property from the south and will primarily <br /> leave the Property in a southbound direction. Coulson also decreased its maximum expected <br /> daily truck trip total to two hundred and twenty (220) one-way trips. This equates to <br /> approximately eleven(11)roundtrip truck trips per hour during the peak mining season. Coulson <br /> anticipates that this maximum truck traffic is only likely to occur during the busiest summer <br /> months, and that in several other months of the year,the daily truck traffic will be far less. <br /> e) Environment/Habitat <br /> Area residents also expressed concern that the Project is incompatible with the <br /> surrounding area because the Project would have a variety of negative environmental impacts. <br /> I <br /> Through the referral agency comment period and the engineering reports, Coulson has addressed <br /> and resolved any environmental concerns with the Project. <br /> I <br /> One particular concern was that the Project would negatively impact Preble's meadow <br /> jumping mouse ("PMJM") habitat. Along with approving the Application during the initial <br /> agency referral phase, the United States Fish and Wildlife Service recently sent a letter to <br /> Coulson's environmental consultant, Jerry Powel of Wildlife Specialties, on June 9, 2017 <br /> ("USFWS Letter") regarding the PMJM population and habitat on the Property and the effect of <br /> the Project on the PMJM. The USFWS Letter concluded that "[g]iven your habitat and project <br /> I <br /> descriptions . . . the impacts resulting from the proposed project are not likely to adversely affect <br /> the Preble's meadow jumping mouse." The complete USFWS Letter is attached to this Letter as <br /> Exhibit F. <br /> I <br /> i <br /> % 8 <br /> 48 <br />
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