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<br />RECEIVED <br />Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Attn: Cazl Mount <br />FJ ro / <br />Marvin Moore (Consultant) <br />1570 Ranney, Craig, CO 81625 <br />(970)824-9249 <br />'MAY 3 0 2006 <br />Division of Mieerab and Seuio,7y <br />rYl - / 948= ~O~ <br /> <br />RE: Reeulatorv Compliance -Moffat County's Gravel Pits <br />Dear Carl:"- - - ....~.__ _ --°---- - --- -- - <br />The purpose of this letter is to discuss the regulatory compliance issues associated <br />with Moffat County's inventory o road maintenance gravel pits. As you aze aware, I <br />have taken Gaze of the permitting requirements for Moffat County for the past twenty <br />years, and I have worked with you and several of the Division of Minerals' employees <br />during that tenure -particularly, since 1991, with Gregg Squire and Barbara Chiappone. <br />$ecause of their retirement, I believe it would be worth while to review some facts that <br />are unique to Moffat County's gravel mining operation. <br />Background <br />Moffat County is the second lazgest county in the state. We have 1843 miles of county <br />roads, most of which are surfaced with crushed rock (road-base gravel). We find it <br />necessary to have 18 permitted construction materials sites stationed along our vast <br />highway network to maintain our county roads, yet we only have one crusher which <br />operates 7 months out of the year. <br />We produce around 70,000 cubic yazds of crushed road-base materials per yeaz, <br />generating approximately 2.5 acres of "new disturbance" in each of two gravel pits, <br />randomly scattered within out`coun`ty road system. We stole ouc Toad-base gravel"in <br />stockpiles from which we haul materials to our construction and maintenance sites as <br />needed. In addition to the road-base, we produce less than 8,000 cubic yazds of "pit-run" <br />materials, as needed, from our gravel pit inventory. Our pit-run gravel is mined from the <br />"disturbed azeas" of the mines, and they generate very little "new disturbance" in the <br />Affected Area of the gravel pits. In summary, out of Moffat County's 18 gravel pits, only <br />2 will suffer a "new disturbance" classification, and 16 will hold a "no new disturbance" <br />classification in any given yeaz, on the average! Cleazly, Moffat County's primary <br />activity is "Stockpile Reduction Only" - no private gravel operator could maintain 18 <br />Mined Land Reclamation Permits to produce only 78, 000 cubic yards of construction <br />materials per year! <br />