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2025-11-24_GENERAL DOCUMENTS - M1986123
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2025-11-24_GENERAL DOCUMENTS - M1986123
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Last modified
11/24/2025 9:26:08 AM
Creation date
11/24/2025 9:19:49 AM
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DRMS Permit Index
Permit No
M1986123
IBM Index Class Name
General Documents
Doc Date
11/24/2025
Doc Name Note
Petition For Reconsideration
Doc Name
Correspondence
From
Witwer, Oldenburg Barry & Groom, LLP
To
DRMS
Email Name
JR2
AME
CMM
Media Type
D
Archive
No
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about this 2023 photograph was extremely misleading and inaccurate. Mr. <br /> Lennberg testified as if he were pointing to lush and robust grass that was growing <br /> upon previously-mined O'Brien property, and testified that this was proof that in <br /> 2023 "the establishment of the vegetation is pretty thick." In actuality, perhaps <br /> without realizing it, Mr. Lennberg was pointing to a part of the O'Brien property <br /> that has never been mined. He pointed to this non-mined area and opined that <br /> "there is adequate topsoil which was able to establish this vegetation that you see <br /> here in the 2023 photo." Based upon the fencepost that is visible in the foreground <br /> of this photo, combined with Mr. Lennberg's testimony that the photo was taken <br /> from the road located at the North end of the O'Brien property, anyone familiar <br /> with the property can decipher that this photograph was actually taken from the <br /> road at the East boundary of O'Brien property facing to the Southwest across a wide <br /> swath of land that has never been mined. See Exhibit B showing the location and <br /> direction of the 2023 photo. Accordingly, when properly interpreted, this photograph <br /> is excellent evidence of just how robust and vibrant the naturally occurring <br /> vegetative cover is, and how difficult it will be to ensure that the areas damaged by <br /> mining activity (the bottom photo in Exhibit A taken in April of 2025). But contrary <br /> to what Mr. Lennberg's testimony suggested, the 2023 photo is certainly not <br /> evidence of the successful revegetation of the mined areas of the O'Brien property. <br /> See Exhibit C, 2023 Aerial post-flood photo (showing that, while the areas near the <br /> Exhibit A 2023 camera were quite green, the areas in the distance from the camera <br /> (North of Pond 3) were in horrible shape). <br /> Third, it is important to note that not just any vegetation will satisfy DRMS <br /> rules. Like quality grasses, noxious weeds are often green in appearance. And <br /> obviously, even without any revegetation efforts at all, bare ground is likely to be <br /> filled in with weeds that are likely to be green in appearance. But noxious weeds do <br /> not satisfy DRMS Rules, and therefore satellite images referenced by Mr. Lennberg <br /> at the hearing are of limited use in distinguishing Rule-compliant revegetation from <br /> non-compliant weed infestation. The same is true about the 2023 photograph in <br /> Exhibit A, where camera was located far from the parts of the O'Brien property that <br /> had supposedly been reclaimed, and little detail can be deciphered with respect to <br /> this area. At the hearing, it was undisputed that the original reclamation plan <br /> required seeding and establishment of high-quality grasses. But the O'Briens <br /> presented a Report from an expert Biologist, Darcy A. Tiglas, explaining how her <br /> on-site evaluation of the O'Brien property found that this was not at all what is <br /> actually growing upon the "reclaimed" O'Brien property. Ms. Tiglas found many <br /> noxious weeds in the supposedly revegetated areas; "little to no grazing value for <br /> 8 <br />
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