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PERMFILE134908
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PERMFILE134908
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Entry Properties
Last modified
8/24/2016 10:35:38 PM
Creation date
11/26/2007 2:52:28 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1979191
IBM Index Class Name
Permit File
Doc Date
4/30/1980
Doc Name
NOTICE OF PROTEST
Media Type
D
Archive
No
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. • iii iiuiiiiiiiu iii <br /> <br />MINE LAND RECLAMATION <br />~~~~~~~~ <br />APR 3 0 198D <br />MINED LAND RECLAMA710N <br />Colo. Dept. of ^!??~!~zl Reso~~rces <br />COLORADO DEPARTMENT OF NATURAL RESOURCES <br />In The Matter of: ) NOTICE OF PROTEST <br />The Permit Application of ) <br />THREE BELL RANCH ASSOCIATES, ) Case #79-191 <br />COMES NOW the Petitioner, Valerie Schuman, by and through <br />her attorney, Robert Justin Driscoll, and protests the granting of <br />a permit to Three Bell Ranch Associates and requests the matter be <br />set for a new hearing on the following grounds: <br />1. That Petitioner owns residential real property immediately <br />continguous to the "Three Bell Ranch" proposed sand and gravel pit. <br />2. That on information and belief, there is newly discovered <br />evidence indicating that the applicant, Three Bell Ranch Associates, <br />did not comply with all applicable local, state and federal la~os <br />pursuant to X34-32-115, C.R.S., 1973, in that: <br />a. No final approval was given by the Larimer County <br />Board of County Commissioners as indicated by a letter <br />dated April 21, 1980, from the Larimer County Attorney's <br />Office attached hereto as Exhibit A and incorporated by <br />reference herein. <br />b. The alleged "final" Findings and Resolution of the <br />Board of County Commissioners of Larimer County dated November <br />28, 1979, attached hereto as Exhibit B, were not complied <br />with in the following particulars, but not limited to: <br />i) There was no acceptable road improvement plan <br />submitted to the County within the required 90 days. <br />ii) The hydrological study was not completed by a <br />qualified hydrologist with an engineering degree. <br /> <br />
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