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<br />Addendum to Rational for Approval Recommendation Page 8 <br />Application for Stone Gravel Pit <br />Permit No. M-97-089 <br />February 17, 1998 <br />DMG informed Ms. Campbell Bell of DMG's decision to withdraw its RTB in a letter dated <br />1/27/98. DMG's 1/27/98 correspondence to Ms. Campbell Bell also informed her of the <br />correct procedure to follow should she desire to bring this matter before the Board. As of <br />the date of this document, DMG has not received a request to bring the matter of DMG <br />withdrawal of its RTB to the Board. <br />DMG has reviewed the BLM 2/10/98 correspondence to Ms. Bell, in which the BLM <br />indicates that their recent site inspection located 18 test pits within the proposed permit <br />area. BLM estimated that total disturbance created by all 18 test pits totaled <br />approximately 0.1 acre. <br />(43,560 sq.ft.lacre) ' (0.1 acre) = 4,356 sq.ft. total disturbed area estimated by BLM <br />Given the total disturbance of 4,356 square feet, estimated by the BLM, and the <br />approximate locations of the test pits indicated by the BLM, the applicant does not appear <br />to have violated the conditions of Rule 1.1113). <br />Given the maximum disturbance of 13,500 square feet, suggested by the objector, and the <br />locations of the test pits indicated by the BLM, the applicant does not appear to have <br />violated the conditions of Rule 1.1113). Under Rule 1.1(13), it is possible for an operator <br />to disturb 3,200 square feet per acre, over approximately 68 acres, and remain in <br />compliance without submitting a Notice of Intent. <br />Please note that DMG authority is limited to enforcement of the Act, Rules and <br />Regulations. Possible damage to sites of historical and archaeological significance by non- <br />mining and non-exploration activities are non-jurisdictional issues for DMG. <br />Objections not related to the Technical Revision but addressed previously in the <br />Proposed Pre-Hearing Conference Order <br />8. Wafer run-off issues have already been raised for presentation at the forma/ hearing. <br />However, it bears repeating here that the app/icant has not presented adequate hydrological <br />in/ormat/on. These problems inc/ude applicant's refusal to present to DMG a stormwater <br />management plan that he has allegedly a/ready doveloped. <br />Issues relating to the adequacy of Exhibit G, Water Information, are identified in the <br />Proposed Pre-Hearing Conference Order, item 6, and are addressed in DMG's 1 /20/98 <br />Rationale for Approval Recommendation, item 6. <br />Issues relating to the adequacy of Exhibit M, Other Permits and Licenses, and specifically <br />