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,,,: Pace ai3e <br />• • <br /> <br />permits for activicies affecting wetlands pursuant to section ao4 <br />of the CWA. <br />FACTUAL ALLEGATIONS GIVING RISE TO THE CLAIMS <br />A_ T,~e Rockv Flats Buffer Zone <br />8. The proposed sand and gravel strip-mining area is <br />loc:~ted south of the Boulder County line and east of Highway 93 <br />in ~Tefferson County Colorado. Known as the Bluestone Mine, the <br />proposed mining area is located within portions of Sections 3, 4, <br />and 9, Township 2 South, Range 70 West (hereinafter the "Proposed <br />Mining Area"). It consists of 425.3 acres of federal land <br />located within the Rocky Flats Buffer Zone. The eastern 75 acres <br />of the Proposed Mining Area are currently used by the National <br />Renewable Energy Laboratory as a National wind Technology Site <br />(°the>_ NRII, Site°) . <br />9. Defendant DOE purchased the surface rights to the <br />Proposed Mining Area from private individuals in 1974-75. <br />10_ Harold D. Spicer and Charles and Perry McKay own the <br />subsurface mineral rights to the Proposed Mining Area. Spicer <br />has leased his mineral rights to Wesley D. Gonda Co. ("Gonda°), <br />and the McKays have leased their rights co western Aggregates, <br /> <br />.11. 6iAI currently operates a gravel pit and grading <br />facility directly west of the Buffet Zone, adjacent to Colorado <br />Higha~iy 93_ A small portion of the existing WAI mine is within <br />the Buffer Zone_ The existing mine is subject to the terms of an <br />Access and Surface Use Agreement executed by wAI and DOE in 1991. <br />SeoooQ Ararnded Complaint <br />4 <br />