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<br /> <br />proving that this permit can issue in accordance with applicable law. 34-32.5-115(4), C.R.S.. A <br />properly completed application is required before a staff evaluation of the proposal can be made. <br />Alternatively, the staff should recommend rejection of the application based on the first statutory <br />criterion for rejecting applications: the application is incomplete. 34-32.5-115(4)(a), C.R.S.. <br />In the event that staff undertakes a substantive evaluation of the incomplete application, <br />the numerous inadequacies and negative impacts of the proposed operations require that the <br />application be denied. The initial comments and opposition provide sufficient grounds for <br />rejection. The additional grounds that were presented at the informal hearing provide further <br />grotmds and support that the applicant has not met his burden of demonstrating that this <br />application can be approved under the relevant laws and regulations. Therefore, numerous <br />compelling reasons establish that this application be denied. <br />I. The application is incomplete. <br />The application contains numerous inadequacies and omissions. The following is an <br />exhibit-by-exhibit description of the grounds for rejecting the application outright as incomplete. <br />These inadequacies and omissions raise substantive questions which aze also grounds for <br />rejection of the application. <br />A. The maps in Exhibit C and the Mining Plan in Exhibit D do not portray the total <br />area to be mined and do not portray the entire area of affected lands as required by <br />Rule 6.4.3(d) and 6.4.4. <br />Details are provided in Exhibit C only for Units I-V. No detail is provided <br />in Exhibit C for Mining Units VI-XII and beyond. The reclamation map, <br />Exhibit F, indicates clearly that mining operations are contemplated for the <br />entire North-South span of the permit azea. <br />2. Although "affected land" includes private ways and roads, existing roads <br />have not been included on Exhibit C, as required. <br />Roads created by the applicant aze not included in the application or any <br />amendments thereto. A road proposed for the north end of the azea is not <br />included the application materials. <br />B. The timetable in Exhibit D only covers Units I-IV. The timetables do not <br />contemplate the time required to excavate and/or protect the identified cultural <br />