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~~ ~ • • <br />BEFORE THE MINED LAND RECLAMATION BOARD <br />STATE OF COLORADO <br />STATEMENT OF OBJECTION TO PETITION FOR RECONSIDERATION <br />IN THE MATTER OF THE APPLICATION OF HALDORSON AND SONS, INC., <br />FILE NO. M-2003-037 <br />Haldorson and Sons, Inc, (Haldorson) the applicant and petitioner herein filed a <br />Petition For Reconsideration of the Mined Land Reclamation Boazd (Board) decision of <br />December 12, 2003, in the above referenced matter. Those entities and individuals <br />represented by undersigned counsel, already as a matter of record herein, respectfully <br />object to the Boazd's consideration of the Petition because it fails to meet the threshold <br />criteria stated in Rule 2.9 regazding newly discovered material, not available to applicant <br />prior to the hearing. Further, objection is made to the substance and request made in the <br />Petition. <br />In support of the foregoing objections, the following comment and response of <br />WestWater Associates, Inc., Objector's hydrologic expert, is respectfully attached hereto, <br />incorporated herewith and submitted to the Board. <br />WHEREFORE, Objectors request that the Board deny consideration of the <br />Petition based upon the petitioner's failure to demonstrate compliance with the threshold <br />requirements of Rule 2.9, and further, in the event that the Board entertains the Petition, <br />Objectors request that the Board deny the Petition in its entirety and make no <br />modifications to the Boazd's December 12, 2003 Findings and Order. <br />