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III IIIIIIIIIIIIIIII 3 <br /> 999 RECEIVED <br /> BEFORE THE MINED LAND RECLAMATION BOARD JUN 0 5 1997 <br /> STATE OF COLORADO Division of Minerals d Geology <br /> File No. M-81-302 <br /> PRE-HEARING STATEMENT OF WESTERN MOBILE AND REQUEST FOR PARTY <br /> STATUS <br /> IN THE MATTER OF THE WESTERN MOBILE - DEEPE FARM PIT- RECLAMATION <br /> PLAN AMENDMENT REQUEST 02 <br /> As the applicant for an amendment to an approved reclamation plan for the Deepe Farm Pit <br /> located in unincorporated Boulder County, Western Mobile, Inc. (Western Mobile), by and through <br /> its attorneys, Parcel, Mauro, Hultin & Spaanstra, P.C., herein requests party status for the formal <br /> hearing on this matter scheduled to be heard before the Colorado Mined Land Reclamation Board <br /> ("MLRB") on Wednesday, June 25, 1997. This pre-hearing statement is submitted in conformance <br /> with the Proposed Pre-Hearing Conference Order sent to interested parties in this matter by the <br /> Division of Minerals of Geology ("Division") on or about May 21, 1997. Since the pre-hearing <br /> conference order will not be finalized until sometime after the June 5, 1997 pre-hearing conference, <br /> Western Mobile reserves the right to supplement and amend this pre-hearing statement as may be <br /> necessary subsequent to the issuance of the final pre-hearing order. <br /> I. STATEMENT OF FACTS <br /> 1. On January 11, 1982, the Boulder County Board of County Commissioners (Board <br /> of County Commissioners")approved a use by special review requested by Flatiron Sand & Gravel <br /> Company (`Flatiron") to mine and process sand and gravel on the first two stages of a six stage <br /> construction materials mining project located at the Deepe Farm Pit in unincorporated Boulder <br /> County. Construction materials mining first occurred in the area of the Deepe Farm Pit in the early <br /> 1950's. <br /> 2 The project approved by the Boulder County Board of County Commissioners <br /> consisted of 168.5 acres of land, the scope of which was reflected on maps entitled "Alternate <br /> Excavation Plan Map"and"Reclamation Plan Map." These maps were submitted by Flatiron to the <br /> Division with the original mining permit application on December 24, 1981. The"Reclamation Plan <br /> Map"contemplated,among other things,the installation of three(3) pit lakes and 41.5 acres of water <br /> surface. <br /> 3. On April 22, 1982 the Colorado MLRB issued Flatiron Permit M-81-302 to mine <br /> sand and gravel from the Deepe Farm Pit and to reclaim the site. The processing plant commenced <br /> operation in August, 1984. Mining and processing of sand and gravel continued at the Deepe Farm <br />