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<br />~ M iii iiiiiiiiiiiuiii <br />MINED LAND RECLAMATION BOARD AUG "3 1989 <br />STATE OF COLORADO M!M[:D LkT~CJ <br />RECIAMA'i"I<)N J~vi~"nr~ <br />REQUEST FOR PARTY STATUS OF CONCERNED CITIZENS FOR WILLIAMS <br />CANYON and JOHN COVERT, AS AN INDIVIDUAL <br />IN THE MATTER OF CASTLE CONCRETE COMPANY, SNYDER QUARRY, EL <br />PA5O COUNTY, <br />Permit No. M-77-210 (Violation Hearing) <br />Concerned Citizens for Williams Canyon ("CCWC") by <br />and through John Covert and John Covert as an individual <br />hereby requests status as a party in the Formal Public <br />Hearing to be held by the Mined Land Reclamation Board <br />("MGRS") on August 23, 1989 regarding the matter of alle~.;ed <br />violations in the above referenced matter; and as ground: <br />therefore, states to the Board as follows: <br />1. There is now pending before the Board a <br />matter captioned "In the Matter of Castle Concrete Company, <br />Snyder Quarry Amendment, Permit No. M-77-210, AM-03" which <br />concerns the same permit which is the subject of the alleged <br />violations to be heard at the Formal Public Hearinq. In <br />said Amendment matter, pursuant to the Supplemenmtal <br />Prehearing Order dated June 29, 1989 issued by the Board,• <br />CCWC and John Covert were admitted as parties to the <br />proceeding and allowed to participate. <br />2. John Covert, on behalf of CCWC, submitted a <br />written complaint to the MLRD on June 30, 1989 to which was <br />attached an exhibit captioned "Photographic Record of <br />Condition: Williams Basin June 6, 1989." Said exhibit <br />includes a written statement and description of photographs, <br />nineteen color slides, and a map indicating the location of <br />each photograph and camera orientation. Said complaint <br />concerns off-site impacts (ie. rock slides) which is one <br />subject of the violation hearing scheduled for August 23, <br />1989. <br />3. CCWC and John Covert should be admitted as a <br />party to the subject hearing as a person who may be affected <br />or agrieved by decisions to be made at the subject hearing. <br />4. CCWC and John Covert represent broad <br />community interests affected by the above-referenced MLRB <br />permit. <br />5. John Covert as an individual and representing <br />CCWC was present during the August 21, 1989 Pre-Hearing <br />Conference held in the MLRB offices and attended by all <br />