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PERMFILE42757
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PERMFILE42757
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Entry Properties
Last modified
8/24/2016 10:45:11 PM
Creation date
11/20/2007 11:18:20 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2005080
IBM Index Class Name
Permit File
Doc Date
8/14/2006
Doc Name
Opposition to Objectiors Motion for Conditions
From
Temkin Wielga Hardt & Longenecker LLP
To
DRMS
Media Type
D
Archive
No
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provisions already contained in Allen's mine plan or existing laws and regulations, and are <br />therefore annecessazy and redundant. t <br />Each of the requested conditions is addressed below. <br />1. Proposed Condition on Groundwater Usaee. Objectors request that Allen's <br />permit include a condition requiring Allen to amend its permit application prior to mining to <br />include an engineering report addressing potential hydrologic impacts from Alien's proposed <br />water supply well. Objectors also request that the Permit include vazious provisions requiring <br />Allen to comply with Colorado water laws and to provide to the Division of Minerals and <br />Geology ("DMG") an approved substitute water supply plan or augmentation plan for the well. <br />The requested condition is unnecessary, redundant and beyond the authority of the Boazd <br />to impose. Colorado water rights aze primarily administered by the Division of Water <br />Resources, and not by this Board. The Boazd's Rules and Regulations for the Extraction of <br />Construction Materials ("Rules") cleazly specify that an applicant is obligated to comply with <br />Colorado water laws, and Objectors' request for duplicative permit conditions is unfounded. <br />Rule 3.1.6(1)(a). <br />Rule 6.3.6 requires that an applicant provide the DMG a statement identifying permits <br />and approvals that "are held or will be sought" by [he applicant in order to conduct the proposed <br />operations. That Rule cleazly contemplates that an applicant may concurrently seek Boazd <br />approval of a reclamation permit, while it is pursuing other necessary permits, and does not <br />require this Board to review all other permits that may be required for a proposed mining <br />' Allen objects to all new azguments raised by Objectors after [he close of the public comment period on Mazch 24, <br />2006. C.R.S. § 34-32.5-114 mandates that all comments to an application "shall be fi]ed with the board or office not <br />more than twenty days after the date of last publication of notice made pursuant [o Section 34-32.5-112(9)" <br />(emphasis added). Thus, consideration of any new argument for denying the application is in direct contradiction to <br />the statute. As acknowledged by [he Division in its application form, "the Office is not allowed to consider <br />comments, unless they are written and received prior to the end of the public comment period" (see Exhibit 5 at p. <br />7). Therefore, the Board should summazily deny all new arguments. <br />
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