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<br />(c) Any part of the proposed mining operation, the reclamation program, or the <br />proposed future use is contrary to the laws or regulations of this article. <br />However, the Neighbors failed in their Objection to specify any aspect of the Application <br />that is contrary to any of the laws or regulations of the article in question. In fact, the <br />Application is fully compliant with all pertinent laws and regulations, and should be <br />approved by the Board. <br />III. Other Issues Raised by the Neighbors <br />The only issued raised by the Neighbors that even conceivably falls within the <br />Board's jurisdiction is the concern the Neighbors raised that the Applicant has not <br />demonstrated that adequate plans have been made to address storm water runoff and that <br />the Applicant has not obtained a CDPHE storm water discharge permit. As of this date, <br />both the storm water discharge permit and the APEN permit have been issued. They had <br />been applied for on the date the Objection was filed. Copies are attached. <br />IV. Conclusion <br />For the reasons set forth above, the Objection filed before this Board by the <br />Neighbors is completely groundless, and the Neighbors have raised no issue that would <br />give this Board any reason to reject the Gravel Pit Application for any reason under its <br />jurisdiction. If this Board has the authority to fine the Neighbors for raising frivolous and <br />groundless objections or to award attorney fees and costs to the Applicant they are hereby <br />requested. <br />V. Request for Expedited hearing <br />Applicant respectfully requests a hearing on this objection on an expedited basis <br />to have gravel available and construct a road this construction season. <br />Dated this /1/?t day of July, 2010. <br />email: pmontano@troutlaw.com <br />Trout Raley Montano Witwer and Freeman P.C. <br />1120 Lincoln Street, Suite 1600 <br />Denver, Colorado 80203 <br />tel: 303.339.5833 <br />fax: 303.832.4465