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Winkler Light Aggregate Quarry August 14, 1989 Page 2 therefore, casts doubt on the MLRD's ability to manage a project of this magnitude. 2. Applicant's inability to address/resolve off-site impacts of the operation. According to the application, 95% of the traffic generated by the operation will use all or a portion of Town roads which are currently substandard for trucking traffic because they are narrow and unpaved. The use of these roads by trucks hauling for the mine will cause rapid degeneration of the system, safety hazards at substandard intersections, and high dust levels. The long-term maintenance of these roads will be the responsibility of the Town with no apparent compensation from the mine operator for improvements or maintenance. Tonage taxes paid by the trucks using the Town roads go to the State to be divided by the counties, with a very small amount coming to the Town. These taxes do not come close to covering the costs for maintenance, let alone initial improvements to eliminate dust problems and safety concerns related to narrow, unimproved roads. The applicant does not propose to widen or add lanes to the principal truck routes and makes no mention of any paving. 3. The need for Douglas County Mineral Extraction Plan in place prior to approval. Because Douglas County is in the process of developing a Mineral Extractions Plan (master planning to identity acceptable areas for mining within the County); because the County is attempting to redefine tax contributions of mining operation to make them more equitably pay their way; and also because the County is working on regulations which will affect industrial traffic allowances on roads servicing primarily residential and agricultural areas, the Town strongly urges the MLRD to deny this permit until local regulations are in place to adequately address an operation of this magnitude and impact upon the Town's infrastructure and resources. In summary, the Town of Castle Rock strongly urges the MLRD to consider all factors raised in this letter as its review of the Winkler Light Aggregate Quarry application. In summation, the Town recommends that the MLRD deny the application, based upon the following reasons: