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exposes the City to potentially great loss and injury to legitimate economic and governmental <br />interests. Not only would the City be required to staff and finance such emergency responses with <br />real economic impacts, but any response to the quarry site or the Wastewater Treatment Plant <br />removes emergency personnel from their regular duties within the City limits, thereby compromising <br />the emergency response services within the City. <br />Accordingly, the City of Black Hawk has demonstrated that it will suffer "actual loss or <br />injury," or will be exposed to "potential loss or injury," to multiple recognized and legitimate legally <br />protected interests. Therefore, the City of Black Hawk has shown that it meets the standard for <br />standing established by the Colorado Supreme Court and adopted by the Act and the MLRB. <br />Therefore, the City respectfully requests that the Boazd enter an order in this matter <br />affirmatively stating that Black Hawk is an "aggrieved person" with standing to be a party to and to <br />file objections in the proceedings regazding the application herein. <br />Respectfully submitted this 17~h day of November, 2005. <br />HAYES, PHILLIPS, HOFFMANN & <br />CARBERRY, P.C. <br />By: ~ ~ 4/------ <br />Corey Y. offm <br />ATTORNEYS FOR OBJECTOR CITY <br />OF BLACK HAWK, COLORADO <br />