2006-06-12_REVISION - M1978314 (2)

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Mined Land Reclamation Boazd June 12, 2006 Page 10 are substantially amplified. With a lazge volume of gravel trucks, it would be extremely dangerous to pull a horse trailer, move cattle, drive a tractor or let a child ride a horse on these roads. Finally, there are two, single-lane substandazd bridges along the route to be utilized by the gravel operation. On information and belief, it appeazs the gravel pit operator has refused to pay to replace the bridges and, instead, wants taxpayers to subsidize his gravel operations by doing so. Effectively, the gravel pit operator is attempting to use six miles of county road as his mine's "haul road." Standazd road engineering demonstrates that the roads will need to be paved to withstand the increased and heavy truck traffic. Transportation and related safety concerns clearly dictate that changes be made to the roads, bridges, highway entrances and ways of egress before a 112 Permit is issued to King Mountain, not after. d. Cattle Movement Among other things, the Ranch Owners are in the cattle business. The Ranches must move their cattle frequently, and often the only route for such movement from the ranches is CR 3 -which, of course, means that the cattle must be moved past King Mountain's gravel pit. Declaration of Wayne Shoemaker, ¶3, attached hereto as Exhibit F (the "Shoemaker Affidavit"). Currently, that passage is not an issue because King Mountain's mining is minimal. Id. Further, when Hewes operated the gravel pit, the operation was generating, at most, 8,000 to 10,000 tons on an annual basis. Id. at ¶4. To the extent the Permit Conversion Application is granted and King Mountain generates the anticipated traffic and dismption, the Ranch Owners will need to either change the time of day at which they move cattle, or shut down truck traffic. Id. at ¶5. When cattle movement is disturbed, there is potential for weight loss, injury, disease and, therefore, decreased production. Id. at ¶6. As a result, expansion of the King Mountain gravel operation could have a severe economic impact on the Ranch Owners' respective cattle ranching businesses. Id. at ¶7. On a sepazate but related issue, dust affects the growth of the grass used for cattle grazing.9 An expansion of the gravel pit to the size proposed by King Mountain will inevitably increase dust (from increased truck traffic), which will have yet another economic impact on the Ranch Owners' ranching businesses. e. Aesthetic and Recreational Concerns The geographic azea that will be affected by an expanded gravel operation is unique, pristine, peaceful and quiet. For the following reasons, expansion of the gravel operation will be s To date, King Mountain has not maintained dust control at the gravel pit. Specifically, it has not maintained a sufficient number of water trucks to reduce the dust on CR 3. Shoemalrer A~davrt at ¶8. Nor, as discussed in subsection f. above, does King Mountain have the water rights necessary to do so. \\\Ua ~ R9080~0801 - 866818 vl