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Mined Land Reclamation Boazd <br />June 12, 2006 <br />Page 12 <br />livestock on the property. Finally, just one yeaz after taking over the operations of the gravel pit, <br />King Mountain's new operator failed to timely file King Mountain's 2005 annual report or the <br />related annual fee (and had to be reminded on numerous occasions by the DMG). Given this <br />pattern, combined with King Mountain's failwe to post a financial warranty and the detrimental <br />impact the proposed gravel operation expansion will have on all of the interests identified by the <br />legislatwe as requiring protection, the Boazd should deny King Mountain's Permit Conversion <br />Application. <br />C. Conclusion <br />For the many reasons set forth above, we respectfully request that the Boazd grant the <br />Ranches party status in this matter. In addition, at this time, the Board does not have jurisdiction <br />to take any action with respect to the Permit Conversion Application filed by King Mountain. <br />Further, King Mountain's proposal has serious economic, environmental, conservation and other <br />ramifications for Routt County and its property owners for years to come, ramifications which <br />the Board is statutorily mandated to consider. Therefore, the Boazd should deny King <br />Mountain's application. <br />The Ranch Owners appreciate yow attention to the issues raised in this letter and <br />respectfully request that this letter, and the exhibits hereto, remain a part of the record of these <br />proceedings. The Ranch Owners reserve the right to supplement these comments prior to the <br />close of the Boazd's public hearing on these matters, and as otherwise appropriate. <br />Very sincerely yours, <br />HOGAN & HARTSON, LLP <br />By. ~~~ <br />Andrew L. Spielman (#29341) <br />Tamera D. Westerberg (#29859) <br />ATTORNEYS FOR SLEEPING LION RANCH, <br />LLC d/b/a BAR-A-RANCH, ER RANCH, LLC, <br />ALFRED FISHER, EGERIA PARK, LLC and <br />CARLLUPPENS <br />cc: Glenda Williams, Secretary of the Board <br />Erica S. Crosby, Division of Minerals & Geology <br />Tyson Powell, Esq. <br />Tanya Light, Esq. <br />Alfred Fisher (via electronic mail) <br />Cazl Luppens (via electronic mail) <br />\\\DE ~ 59060NOW ~ 265818 vl <br />