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2006-05-30_REPORT - M1998003
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2006-05-30_REPORT - M1998003
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Last modified
8/23/2019 8:46:37 AM
Creation date
11/27/2007 1:23:10 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1998003
IBM Index Class Name
Report
Doc Date
5/30/2006
Doc Name
Adequacy Review Response
From
Marvin Moore
To
DMG
Permit Index Doc Type
Annual Fee / Report
Media Type
D
Archive
No
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(Sentence #3) <br />"The annual Report and Fee requirement is not met until we have received the <br />following 3 components: fee, renort, and associated maw (all 3 are required <br />regardless of the level of disturbance or absence of disturbance during the <br />previous year). (Emphasis added) <br />Which is it? Do I file "either a written report or an adequately labeled map" on the <br />Raftopoulos pit under sentence #2. Or, aze both the report and associated map required <br />under sentence #3: "regardless of the level of disturbance or absence of disturbance <br />during the previous year"7 <br />In order to sort this out, I have reviewed The Mineral Rules and ReQUlalions for the <br />Extraction oLConstruction Materials, promulgated October, 1995.(amended.Apri12005) <br />posted on the Division of Minerals and Geology's home page: <br />Rule 1.15 (2) <br />"...If no new disturbances or reclamation have occurred during the <br />previous year and no changes to the previous year's map are necessary, then no <br />new map is required, provided the Operator shall state this in the annual <br />report. " <br />In sentence #2, I can find no provision in Rule 1.15 granting the Permittee the option <br />of filing: <br />"... [E]ither a written report or an adequately labeled map", however, I have no <br />quan•el with sentence #2 because it shows flexibility in the application of the Rule. <br />However, I do take exception to sentence #3 demanding that the report and associated <br />map; <br />"...are required regardless of the level of disturbance or absence of disturbance <br />during the previous year" <br />Unless Rule 1.15 (2) above has been repealed, it is my personal opinion that this Rule <br />grants the "Operator"the option (and the right) to omit a new map: <br />"...If no new disturbances or reclamation have occurred during the previous <br />year and no changes to the previous year's map are necessary." <br />Requiring Moffat County to file a new map on 18 gravel pits every year "regardless of <br />the Zevel of disturbance or absence of disturbance during the previous year" would be <br />like requiring the Division of Minerals and Geology to make an annual inspection on <br />each of our pits, separately, on their respective anniversary dates. <br />
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