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Determination of Standing, filed with- the Boazd on November 17, 2005, which is hereby <br />incorporated by reference.. In short, the City's documented and recognized water rights (real property <br />rights pursuant to C.R.S. § 38-30-102) aze put in jeopardy by this application; the City's documented <br />and recognized economic and governmental interest as part owner in the Black-Hawk Central City <br />Sanitation District Wastewater Treatment Plant aze put in jeopazdy by this application; and the City's <br />documented and recognized economic and governmental interest as the primary emergency <br />responder to calls for emergency services along the Highway 119 Corridor aze put in jeopazdy by this <br />application. <br />To the extent that the Applicant argues that the City has not timely raised these issues and <br />that, by operation of some azbitrary deadline, the City's legitimate and substantive property, <br />economic, and governmental interests should not be considered by the Boazd in the proceeding, <br />Applicant's argument must be rejected for at least two reasons. First, the City raised its objections <br />based on the proposed mine's potential impact on the area's water supply as early as December 30, <br />2004, in its letter to Tom Schreiner re: Objections to Reclamation Permit Application # 2004-067 <br />(Black Hawk's Exhibit 109). At this time, the City also raised concerns related to Highway 119 <br />access. This was a timely objection to the Applicant's original application, which the Division of <br />Minerals and Geology ("DMG") considered to be filed on November 9, 2004. <br />The City reiterated and expanded on its objections in its May 25, 2005, letter to Tom <br />Schreiner re: Objections to Amended Reclamation Permit Application # M-2004-067 (Black Hawk's <br />Exbibit 156). This was a timely objection to the Applicant's amended application, considered filed <br />by DMG on April 11, 2005, which amendment triggered new notice requirements and a new <br />City's position in this matter, the City responds to the Applicant's motion as follows. <br />3 <br />