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999 RFGEIVED (� <br /> JUN 131991 <br /> BEFORE THE MINED LAND RECLAMATION BOARD, STATE OF COLORADO <br /> File No. M-81-302 oivioion of M111"16 u Goo eHY <br /> AMENDED PRE-HEARING STATEMENT OF THE CITY OF BOULDER, COLORADO <br /> IN THE MATTER OF THE WESTERN MOBILE - DEEPE FARM PIT - AMENDMENT 02 <br /> The City of Boulder, Colorado (the "City") submits the following amendments to the Pre- <br /> Hearing Statement submitted by the City on June 4, 19 <br /> 97: <br /> 1. Paragraph #1 of Section I.C. shall be amended as follows: <br /> The application is incomplete and the Division acted on it in violation of Construction <br /> Material Rules 6.4.4, 6.4.5, 6.4.18, and 6.4.19. As such, this Board should require the <br /> applicant to re-submit a complete application. The City has been unable to review a <br /> complete application of extreme importance to our citizens due to its inadequacy. <br /> 2. Section H., LIST OF WITNESSES, is amended with the addition of the following witness: <br /> F. Dr. David Cooper. Dr. Cooper or one of his associates will testify about the habitat <br /> on adjacent properties, particularly City open space lands. More specifically, Mr. <br /> Cooper will focus on the Ute Ladies' tresses Orchid and the Preble's Meadow <br /> Jumping Mouse and their habitat, and the impacts that may occur to that habitat from <br /> the reclamation plan. <br /> 3. Section III.A. of the Exhibits is stricken in its entirety and replaced with the following: <br /> 1. 1986 reports generated by William F. Jennings in connection with the discovery of <br /> the existence of Spiranthes diluvialis on City of Boulder Open Space. <br /> 2. 1990 Spiranthes diluvialis Research Plan compiled by Nina Williams, Agricultural <br /> Research Assistant for City of Boulder Open Space Department. <br /> 3. United States Department of the Interior <br /> Fish and Wildlife Service <br /> ES/TE/Ute ladies'-tresses Recovery Plan dated September, 1995. <br /> 4. Letter from City of Boulder Open Space Operations dated January 26, 1996 to the <br /> US Fish and Wildlife Service. <br /> KN LPHA�CMWMT-APHSJA.0 <br />