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DECLARATION OF WAYNE SHOEMAKER <br />I, Wayne Shoemaker, pursuant to 28 U.S.C.A, § 1746, hereby declare under penalty of <br />perjury under the laws of the United States of America the following: <br />]. I am the ranch manager at Sleeping Lion Ranch d/b/a Bar-A-Ranch, and ER <br />Ranch, LLC, in Toponas, Colorado. <br />2. I also have working knowledge of the cattle business at the ranch known as Egeria <br />Park, LLC, also located in Toponas, Colorado. <br />3. Each of the Ranches must move their cattle frequently, and often the only route <br />for such movement from the ranches is county road 3. That means that the cattle must be moved <br />past King Mountain Gravel's grave] pit. Currently, the mining at King Mountain's gravel pit is <br />minimal so the frequent cattle movement is not a problem. <br />4. At the time that Frank Hewes operated his gravel pit, prior to its transfer to King <br />Mountain, the mining operation was generating, at most, 8,000-10,000 tons on an annual basis. <br />5. If King Mountain's proposed expansion of the gravel operation is approved, the <br />ranches will need to either change the time of day that they move their cattle, or shut down the <br />truck traffic, <br />6. When cattle movement is disturbed, for any reason, there is the potential for <br />weight loss, injury and disease. As a result, there is potential for decreased production. <br />7. Expansion of the King Mountain gravel operation could have a severe economic <br />impact on the cattle ranching businesses at the ranches. <br />8. King Mountain has not maintained dust control at the gravel pit because it has not <br />maintained a sufficient number of water trucks to reduce the dust on County Road 3. <br />9. Visitors frequent Toponas and the ranch lands for recreational purposes, including <br />horseback riding, hiking, hunting, snowmobiling, snowshoeing, cross-country skiing, and fishing. <br />10. King Mountain previously used a "temporary pit entrance" as a long term <br />entrance to the gravel pit. That temporary pit entrance was in a very dangerous location. <br />\\\D& ~ 47060/0001 ~ 286081 vt <br />