PERMFILE41904

• Permit No: M2004067
• IBM Index Class Name: Permit File
• Doc Date: 8/19/2005
• Doc Name: 2nd Adequacy Response
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

~~ Banks and Gesso, LLC
~~
August 19, 2005
720 Kipling St.,Suite117
Lakewood, Colorado 80215
[phone]
Fax [phone]
www. banksandgesso.com
RECEII/Ep
Tom Schreiner
Colorado Division of Minerals and Geology AUG 19 2005
1313 Sherman St., ROOM 215 BivislonefMinerelsandGeoloAY
Denver, CO 80203
Re: MMRR Quarry, M-2004-067, Response to 2nd Adequacy Review
Dear Mr. Schreiner:
This letter contains the response to the Division of Minerals and Geology
adequacy review comments of June 30, 2005 (as amended August 2, 2005)
regarding DMG Regular 112 permit application M-2004-067.
Technical review has been ongoing for several months, and the scope of
adequacy review became somewhat enlarged following the initial adequacy
submittal on March 23, 2005, which prompted a new public comment period. We
believe that the current adequacy process, including particularly this response,
defines the fullest possible extent of technical considerations applicable to the
proposed quarry under the Colorado Land Reclamation Act for the Extraction of
Construction Materials ("Construction Materials Act"). In fact, this applicant has
been asked to address issues outside the purview of the Construction Materials
Act and to provide detailed analysis of spurious technical issues, where
applicants in a similar position have not carried the entire burden of keeping the
permitting process focused on the relevant statutes and rules and the reality of
what is proposed.
With the Division's understanding that this applicant has made every appropriate
effort to comply with the statutes and Rules governing the issuance of a
Reclamation Permit, please note that this adequacy response contains detailed
analysis of stormwater runoff, vibrational effects, and the presence of radioactive
materials prior to and during quarry operations. In addition to the exceptional
coverage of these topics, the adequacy process has comprehensively examined
the exhibits and rules relevant to all aspects of mining operations and
reclamation. The analysis and mitigation measures developed through this
adequacy process meet or exceed all applicable standards under the
Construction Materials Act.
~~