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HomeMy WebLinkAbout2.0 BOCC Staff Report 04.21.2008TO FROM DATE j ~· MEMORANDUM Board of County Commissioners Building and Planning Department, Fred Jarman November 13th, 2007 Referral of a Conditional Use Permit for an "Extraction and Processing" for construction materials I. BACKGROUND The Building and Planning Department received a Conditional Use Permit (CUP) application for an "Extraction and Processing" comprised of a quarry site for Marathon Oil Company located 9 miles up Garden Gulch Roa d off of County Road 215 . The Town of Parachute is located 10 miles southeast. The owner of the property is Berry Petroleum. More specifically, the Applicant requests approval from the Board for an "extraction and processing" site to accommodate the Circle Dot Quarry construction material mine site in the Resource· Lands -Plateau zone district. The proposed facility is proposed to encompass 10 acres of the 334 acre parcel. The proposed quarry will extracted primarily shale to produced construction material for operations in the area. The gravel mine is located on a private road and material produced from this site will be transported on private roads the entire route. The facility is proposed to accommodate 1-2 operators, around 6 dump trucks trips per day and the lifespan will be dependent on mineral resource requirements of the property owner. Photo of the Proposed Circle Dot Quarry Site II . REQUEST The application is for an "Extraction and Processing" site for a material mine site not to exceed 10 acres in size in the RL zone district. III . REFERRAL AUTHORJTY Section 9.02 .03 of the Zoning Resolution of 1978, as amended requires that Conditional Use Permit applications be initially brought to the Board so that the Board may determine if a recommendation from the Planning Commission is necessary. IV. STAFFRECOMMENDATION Staff finds that due to 1) the limited nature of potential impacts to surrounding properties due to the topography, 2) the fairly remote location of the facility, 3) materials produced from this mine will be transport on private roads and will have minimal impact on the county road system, Staff recommends the Board direct Staff to schedule a public hearing for the Board and not refer the matter to the Planning Commission. BOCC 04/21/08 FJ PROJECT INFORMATION AND STAFF COMMENTS TYPE OF REVIEW APPLICANT PROPERTY OWNER LOCATION SITE INFORMATION EXISTING ZONING COMPREHENSIVE PLAN Conditional Use Permit for "Extraction, Prosessing, Sterage artd--Material Hanelling ef Natural Resources" for a Construction Materials Surface Mine Marathon Oil Company Berry Petroleum Company 17 miles NW of Parachute in Section 1, T6S, R97W 10-acre site located on an approximately 334-acre property Resource Lands (Plateau) Study Area 5 :fuo /6~JI /hi) :::. I vo I-gt o -::-s-:r, II oo c 1-. ) ,i;,,+t->« ,.(.· ,1ti_) Marathon Oil Company Co ns truct io n M a t erials Mine BOCC-04121 108 Page 2 I. DESCRIPTION OF THE PROPOSAL The Applicant requests approval for a Conditional Use Permit to operate a construction materials surface mine. This proposed use involves removing natural shale I rock I gravel material from an existing hillside located on the plateau to be used exclusively on roads and pads serving natural gas exploration and production in the area . The mine site will comprise a total of 10 acres (equivalent to 9 football fields) once fully mined . The subject property is approximately 334 acres in size and is owned by Berry Petroleum Corporation. The method of extraction is a bulldozer which will dig the material out which is then crushed I sorted and then loaded into dump trucks to be transported to construction sites around the area . The Applicant proposes the life of the extraction activity to depend on the pace and amount of material extracted fo r various needs of the Applicant. The Applicant intends to use the material exclusively for Marathon's gas production projects (primarily roads and pads) in the area which will use private internal roads to haul the material. The Applicant proposes very limited use of CR 215 to commute to the site from the lower valley floor. Hours of operation are proposed from 7:00 AM to 7 :00 PM, Monday through Saturday. Six to e ight dump trucks will be accessing the site every day with between 1 and 2 operators staying at the site daily. Water trucks will be used for dust control as needed . II. BACKGROUND On November 13 , 2007 , Staff brought the proposal to the Board to determine if the application should be referred to the Planning Commiss ion for comment. As a result, the Board did not refer the matter to the Plann ing Commission due to 1) the limited nature of potential impacts to surrounding properties due to the topography, 2) the fairly remote . t--location of the facility, 3) materials produced from this mine will be transported entirely on ~ private roads having very m inimal impact on the County road system , and 4) provide an \ A "on -site location for gravel rather than placing additional burden on gravel resources in the '-=\) Colorado valley f loor. Ill. AUTHORITY & APPLICABILITY Pursuant to Section 9 .00 of the Zoning Resolution , an application for a Conditional Use Permit shall be approved by the Board of County Commissioners after holding a public hearing thereon in conformance with all provisions of the Zoning Resolution. Marathon Oil Company Construction Materials Mine BOCC-04121108 Page3 IV. GENERAL SITE DESCRIPTION I LOCATION The site proposed for the surface mining activity is located on a knoll on the plateau described as an open, shrubby, rock formation covered primarily by sage brush, pockets of aspen, service berry and oak brush at about 8,200 feet. (Zoning map below shows location) I , I I I T ·-"" J NU! • Site I I ~'--!l' ,......., I 6 5 c/ 1 3 8 2 j .., ,\ u j h--12 7 8 10 1' 12 ' i:J ' j 13 1~ " io 15 14 f,:J' 24 ,__ 20 tr .., 23 " >n -LJ I - 25 -1 zr .~ 2S --, r1 .... ~ 1--r.. .. I S3 L. ' ~' r 31 ' --,...., 1 , __ ~ -"' ~ L '--u 6 4 2 1 12 , j ~ / " Mara thon Oil Co mpany C onstruction Materials Mine B OCC -04121108 Page5 from adjacent uses of land through installation of screen fences or landscape materials on the periphery of the lot and by location of intensively utilized areas, access points, lighting and signs in such a manner as to protect established neighborhood character; Response Staff finds that the location of the mine is beyond a Y4 mile from any adjacent properties and will not be operated at night so no lighting w ill occur. The s ite , once fully mined (10 acres), will comprise an area of approximate ly n ine (9) football fields. The existing "neighborhood character" is that of open range land and o il and gas dril li ng operations. As this is a surface mine, it will change the charact er (visually & topographically) of the immediate area as it is the only surface strip mine in the area and sits on the very top of a knoll on the plateau making it v isible from other similarly situated properties . There will be no publicly visible impact. The operation is required to be reclaimed once fully mined to lessen this impact. The Division of Reclamation , Mining , and Safety (ORMS ) requ ires a bond be held that is pe riodically recalcu lated over time to ensure rec lamation. Standards in Section 5.03.07 for Industrial Operations Industrial Operations: Industrial Operations, including extraction, processing, fabrication, industrial support facilities, mineral waste disposal, storage, sanitary landfill, salvage yard, access routes and utility lines, shall be permitted, provided: (1) The applicant for a permit for industrial operations shall prepare and submit to the Planning Director ten (10) copies of an impact statement on the proposed use describing its location, scope, design and construction schedule, including an explanation of its operational characteristics. One (1) copy of the impact statement shall be filed with the County Commissioners by the Planning Director. The impact statement shall address the following: (A) Existing lawful use of water through depleti on or pollution of surface run-off, stream flow or ground water; Response The mining activity itself does not require permanent domestic water or wastewater services . Th e only water use required at the s ite is to be used for dust control and the Applicant proposes to truck that water in from a licensed water p rovider. Additionally, the application contains a Storm Water Management Plan (SWMP) which is intended to demonstrate how water resultant from a heavy rain event is properly handled so that there is no pollution of surface run -off to surface stream flow. There are no surface streams in the immediate vicin ity of the project site . This SWMP incorporates appropriate Mar ath on Oil Company Construction Materials M ine B OCC -04121 108 Page 6 best management practices employed to handle the drainage of storm water flows specific to erosion and sediment control measures such as topsoil stockpile I diversion berm & ditches, downhill silt fencing, and hay bale I rock check dams , etc. This SWMP is filed with the Colorado Division of Public Health & Environment. The application indicates that an inspection is to occur immediately following rain events and every 14 days to ensure that these BMPs are sill effectively in pJace. (BJ Impacts on adjacent land from the generation of vapor, dust, smoke, noise, glare or vibration, or other emanations; Response The mining activity will consist of the use of bulldozers, loaders, dump trucks, and a rock crusher I screener. There will not be any glare or adverse vapor generated from the use . There will be limited smoke generated from the exhaust of the machinery used to extract and haul the material. Due to the remote location and physical geography of the site, there will be no detectable vibration generated from the use at the boundaries of the property. The mining activity will generate dust which is proposed to be mitigated by watering by trucks . Regarding noise, the Application contains a noise study prepared by Cordilleran Compliance Services, Inc. which ultimately provides that the noise levels at the property boundary (1/4 mile from the operation) would be 47 .6 dB(A) during the day with ambient noise levels at night once the operation is shut down which is less than all of the State's required threshold levels shown below: Zone 7 am to 7 om 7 IJm to 7 am Residential 55 dB(AJ 50 dB(A) Commercial 60 dB(A) 55 dB(A) Light Industrial 65 dB(A) 70 dB(A) Industrial 80 dB(A) 75 dB(A) (CJ Impacts on wildlife and domestic animals through the creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns or other disruptions; Response The Application contained a Wildlife Assessment and Management Plan prepared by Westwater Engineering, Inc. The analys is included date collected from a site visit to observe the plant and animal life at the site location . The analysis describes the habitat of the area and the varied wildlife it could support. The report points out particular raptor nests of Red-tailed Hawk and Cooper's Hawk. While the area meets criteria for greater sage grouse, none were experienced during the visit; however, several blue (dusky) grouse were observed . Staff finds that the proposed use doesn't appear to block any identified migration Marathon Oil Co mpany Co nstruction Materials Min e BOCC -0412 1108 Page 7 routes or will pose as a hazardous attraction; however, it will alter existing native vegetation and use patterns. The report makes the following recommendations for wildlife mitigation on the site which the Applicant stated they would comply with in their application: 1) Improve Greater Sage Grouse Habitat; 2) Minimize footprint of disturbance; 3) Re -seeding; 4) Black Bear Measures; and 5) Raptor timing limitations. Table 2. Timing limitations and NSO recommendations for active raptor nes ts Species Buffer Zone -NSO Seasonal Restriction Red-tailed Hawk 0.33 mile 1 March· 15 July Swainson's Hawk 0.25 mile 1 April -15 Augus t Sharp-sh inned Hawk 0.25 mile 1 April -15 August Cooper's Hawk 0.25 mile 1 April -15 Augu st Peregr ine Falcon 0 .5 mile 15 March -31 July Prairie Falcon 0.5 mile 15 March -3 1 July Go lde n Eag le 0.25 mil e+ a lt. nes ts 1 January -15 July No rthern Harrier 0.25 mile 1 April -15 Au gu st Nort hern Py gmy-Owl 0.25 mil e 15 March -15 Jul y Long-eared Owl 0.25 mile 1 March -15 July Great Horn ed Ow l * * • Great Homed Owls are relatively tolerant of human activity. Keep activ ity to a mi nimum dur ing breed ing season. (DJ Affirmatively show the impacts of truck and automobile traffic to and from such uses and their impacts to areas in the County; Response As mentioned above , the activity at the mine will generate up to 6 dump trucks per day during peak periods of activity . Once the heavy trucks and machinery are brought to and located on site, there will be no impact to the County road system . The loaders accessing the site are all traveling the private road system on top of the plateau to and from projects on top . One of the primary purposes of the mining operation is to produce gravel I construction materials to construct I improve the existing private road system . This will have the effect of lessening the industry's demand on good (and very limited) gravel resources in the Colorado River valley as well as eliminating heavy haul trucks from the County Road system . Marathon Oil Company Construction Materials Mine BOCC-04121108 Page8 (E) That sufficient distances shall separate such use from abutting property which might otherwise be damaged by operations of the proposed use(s); Response Staff finds that the location of the mine is beyond a Y. mile from any adjacent properties and will not be operated at night so no lighting will occur. The site, once fully mined (10 acres), will comprise an area of approximately nine (9) football fields. The existing "neighborhood character" is that of open I native range land and oil and gas drilling operations. As this is a surface mine, it will change the character (visually & topographically) of the immediate area as it is the only surface strip mine in the area and sits on the very top of a knoll on the plateau making it visible from other similarly situated properties; however, there will be no publicly visible impact. The operation is required to be reclaimed once fully mined to lessen this impact. The Division of Reclamation, Mining, and Safety (ORMS) requires a bond be held that is periodically recalculated over time to ensure reclamation. Staff finds sufficient distances are in place (1/4 mile from property lines) and will not affect adjacent properties. (2) Permits may be granted for those uses with provisions that provide adequate mitigation for the following: (A) A plan for site rehabilitation must be approved by the County Commissioners before a permit for conditional or special use will be issued; Response The Applicant proposes a reclamation plan and is required to have an approved plan for the ORMS. The Application contains a plan which is essentially the following: Marathon Oil Company Construction Mat erials Mine BOCC -04121108 Page9 Reclamation wi ll be compl et ed in accordance wi th the Division of Mi ne rals and Geology, Mined Land Reclamation Permit. A reclamation bon d will be posted with the Division o f Minerals and Geology. This permit appli cation i s attached . Re clamat ion will begin at the en d of activit y on s it e. Topsoil that h as been segre gat ed in a pil e to the southwest of t he site will be spread over the reclaimed surface. A t rackhoe will be used to compact and roughen the surface of the top soi l, creating a more favorab le seed bed and dissip ating the effect s of st ormwater erosion. A ll remaining slopes will be re-contour ed and prepared for re-vegetation . A ll s lopes will b e re-seeded and erosion mats 'Nill be u sed on s lopes with grades over 5 p ercent. Re-seeding w ill u tilize a seed m ixture selected by Marathon for its reclamati on ac ti vities in the area. This seed mixture is attached. Re-vegetation will take p lace no sooner than one year after mining has ceased. The seeding will occur b etween Sep tem be r 15th and December 1st. The method o f seed p lacement wi ll like ly be in the form of broadcastin g onto a roughened surface . The mining and reclamation plan in the ORMS perm it app lication basically provides that "Final Stabi liza t ion " has occurred when a un iform vegetative cover with a density of 70% of the pre-disturbance levels has been established or when an equivalent permanent , physical erosion reduct ion method is in place. Staff suggests the Applicant provideFa photo documentation of the pre -disturbance of the site in order to compare to the p ost disturbance. The Applicant does not provide a graphic representation of what the r~c l amation 'wjll look like once completep . - Regarding noxious weeds , the Application contains a Noxious Weed Management Plan prepared by Paller & Girard , Inc. that is a general plan to be applied to lands owned and leased by Marathon O il Company. The plan is specific to this application in the followi ng way: TI1c proposed Rock QuaiTy site is lo cated at N39 33569', W10 8 09.88 4 '. Exis tin g vegeta t ion th is site features Big sagebru sh, Oak, serviceberry, Sn owberry, needlegrasses and L upine. A noxious weed inventory was conducted on Aug ust 1, 200 7 by Pa ll e r & Girard, In c. No nox iou s w eed s were discovered on this s i te. After cons truct ion of the quarry, t he s ite w ill b e rc~inve n tori ed and mapp ed . If any n oxious weeds arc discovered, they will be 1rcated w ith and appropriate h erbicide. (B) The County Commissioners may require security before a permit for special or conditional use is issued, if required. The applicant shall furnish evidence of a bank commitment of credit, bond, certified check or other security deemed acceptable by the County Commissioners in the amount calculated by the County Commissioners to secure the execution Response Marathon Oil Company Construction Materials Mine BOCC-04121108 Page JO of the site rehabilitation plan in workmanlike manner and in accordance with the specifications and construction schedule established or approved by the County Commissioners. Such commitments, bonds or check shall be payable to and held by the County Commissioners; Staff contacted the ORMS which indicated the application is in their technical adequacy review and no permit has been granted and no bond calculation has occurred. Staff suggests the Applicant be required to provide a copy of the bond that has been approved and held by the ORMS prior to the issuance of a Conditional Use Permit. Staff does not suggest the County also request an additional bond. (CJ Impacts set forth in the impact statement and compliance with the standards contained in Section 5.03.08 of this Resolution. (A. 93-061) Section 5.03.08 Industrial Performance Standards Industrial Performance Standards: All industrial operations in the County shall comply with applicable County, State, and Federal regulations regulating water, air and noise pollution and shall not be conducted in a manner constituting a public nuisance or hazard. Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare and odor and all other undesirable environmental effects beyond the boundaries of the property in which such uses are located, in accord with the following standards; (1) Volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes at the time any new application is made. (2) Vibration generated: every use shall be so operated that the ground vibration inherently and recurrently generated is not perceptible, without instruments, at any point of any boundary line of the property on which the use is located; (3) Emissions of smoke and particulate matter: every use shall be operated so as to comply with all Federal, State and County air quality laws, regulations and standards; (4) Emission of heat, glare, radiation and fumes: every use shall be so operated that it does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircra~ warning signals, reflective painting of storage tanks, or other such operations which may be required by law as safety or air pollution control measures shall be exempted from this provision; (5) Storage area, salvage yard, sanitary landfill and mineral waste disposal areas:(A97·112) Marathon Oil Company Construction Materials Mine BOCC-04121108 Page 11 (AJ Storage of flammable or explosive solids or gases shall be in accordance with accepted standards and laws and shall comply with the national, state and local fire codes and written recommendations/comments from the appropriate local protection district regarding compliance with the appropriate codes; (A97-112) (BJ At the discretion of· the County Commissioners, all outdoor storage facilities may be required to be enclosed by fence, landscaping or wall adequate to conceal such facilities from adjacent property; (A97-112) (CJ No materials or wastes shall be deposited upon a property in such form or manner that they may be transferred off the property by any reasonably foreseeable natural causes or forces; (A97-112) (DJ Storage of Heavy Equipment will only be allowed subject to (A) and (C) above and the following standards: (A97-112) 1. The minimum lot size is five (5) acres and is not a platted subdivision. 2. The equipment storage area is not placed any closer than 300 ft. from any existing residential dwelling. 3. All equipment storage will be enclosed in an area with screening at least eight (8) feet m height and obscured from view at the same elevation or lower. Screening may include berming, landscaping, sight obscuring fencing or a combination of any of these methods. 4. Any repair and maintenance activity requiring the use of equipment that will generate noise, odors or glare beyond tlie property boundaries will be conducted within a building or outdoors during the hours of 8 a.m. to 6 p.m., Mon.-Fri. 5. Loading and unloading of vehicles shall be conducted on private propeny and may not be conducted on any public right-of-way. (EJ Any storage area for uses not associated with natural resources shall not exceed ten (10) acres in size. (FJ Any lighting of storage area shall be pointed downward and inward to the property center and shaded to prevent direct reflection on adjacent property. (6) Water pollution: in a case in which potential hazards exist, it shall be necessary to install safeguards designed to comply with the Regulations of the Environmental Protection Agency before operation of the facilities may begin. Response Marathon Oil Company Construction Materials Mine BOCC-04121108 Page 12 These aforementioned performance standards shall be considered conditions of approval should the Board move to approve the Conditional Use Permit. VI. RECOMMENDED FINDINGS 1. Proper posting and public notice was provided as required for the meeting before the Board of County Commissioners. 2. The meeting before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at that meeting. 3. The above stated and other reasons, the proposed conditional use permit has been determined to be in the best interest of the health, safety, morals, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. The application has met the requirements of Sections 5:03, 5:03:07, 5:03.08 and 9:00) the Garfield County Zoning Resolution of 1978, as amended. VII. STAFF RECOMMENDATION Due to 1) the limited nature of potential impacts to surrounding properties due to the topography, 2) the remote location of the facility being 17 miles NW of Parachute, 3) materials produced from this mine will be transported entirely on private roads having virtually no impact on the County road system, and 4) provides an "on-site" location for gravel rather than placing additional burden on gravel resources in the Colorado valley floor, Staff recommends the Board approve the request for a Conditional Use Permit for Extraction, Processing, Storage and Material Handling of Natural Resources for the Marathon Circle Dot Quarry Construction Materials Mine with the following conditions: 1. That all representations of the Applicant, either within the application or stated at the hearing before the Board of County Commissioners, shall be considered conditions of approval unless explicitly altered by the Board. 2. No Conditional Use Permit shall issue and no work can begin at the site until the Applicant has provided the County with an approval from the Division of Minerals and Geology. 3. The Applicant shall provide a copy of the reclamation bond that has been approved and held by the ORMS prior to the issuance of a Conditional Use Permit. Marathon Oil Company Construction Materials Mine BOCC-04121108 Page 13 4. Volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes. 5. Vibration generated The mining activity shall be so operated that the ground vibration inherently and recurrently generated is not perceptible, without instruments, at any point of any boundary line of the property on which the use is located. 6. Emissions of smoke and particulate matter: The mining activity shall be so operated so as to comply with all Federal, State and County air quality laws, regulations and standards. 7. Emission of heat, glare, radiation and fumes: The mining activity shall be so operated that it does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. 8. Storage of Heavy Equipment will only be allowed subject to the following standards: a. Storage of flammable or explosive solids or gases shall be in accordance with accepted standards and laws and shall comply with the national, state and local fire codes and written recommendations/comments from the appropriate local protection district regarding compliance with the appropriate codes; b. No materials or wastes shall be deposited upon a property in such form or manner that they may be transferred off the property by any reasonably foreseeable natural causes or forces; c. Any repair and maintenance activity requiring the use of equipment that will generate noise, odors or glare beyond the property boundaries will be conducted within a building or outdoors during the hours of 7 a.m. to 7 p.m., Monday -Saturday; and d. Loading and unloading of vehicles shall be conducted on private property and may not be conducted on any public right-of-way. 9. That all equipment hauled to the site will abide by Garfield County Road & Bridge Department's oversize/overweight permit system. Marathon Oil Company Construction Materials Mine BOCC-04121108 Page 14 10. That the Applicant shall meet with the County Vegetation Manager and obtain an approval for the proposed noxious weed management plan and submit that approval to the County prior to the issuance of a Conditional Use Permit. 11. The Applicant shall provide an illustrative graphic rendering that shows the topography and vegetation covering established with full reclamation prior to the issuance of the Conditional Use Permit. 12. The Applicant shall provide photo documentation of the pre-disturbance of the site in order to compare to the post disturbance. This information shall be provided to the County prior to the issuance of the Conditional Use Permit. 13. That no activity shall occur at the site until all of these conditions have been met. VIII. RECOMMENDED MOTION "I move to approve a Conditional Use Permit for Extraction, Processing, Storage and Material Handling of Natural Resources for the Marathon Circle Dot Quarry Construction Materials Mine with the conditions provided by Staff." Board of County Commissioners Clo Garfield County Planning Department 108 8th Street, Suite 401 Glenwood Springs, CO April 14, 2008 EXHIBIT JG RE: Circle Dot Quarry Site-Conditional Use Permit Application Dear Commissioners: A public hearing is scheduled for April 21, 2008, regarding the above a pplication that has been filed by Marathon Oil Company and Berry Petroleum Compa ny. At this time, we are unable to attend the meeting ; however, for the reasons set forth below, we are opposing the application and the quarry. We own lots 20 and 21 in Section 1, Township 6 South, Range 97 Wes t; the proposed quarry will be in the East half of lot 23 and the West half of lot 24 in the same Section. As such, lots 20 and 21 will be directly affected by the quarry and the activities conducted there. The quarry is proposed for the extraction and process of shale for construction purposes-in its simplest terms, the quarry is a gravel pit. This proposed use will drastically increase truck and other traffic not only on the Garden Gulch road (the main access from Parachute Creek to Logan Mountain), but on adjacent property owners like us . Further, the traffic and direct operations of the quarry will significantly increase dust and air-borne pollutants, smoke and noise. The level of dust with the current amount of activity in the area is extreme ; for example, Marathon currently maintains a pipe yard and quarry in Section 32, and problems the proposed quarry will bring can be found in the operations of the Marathon quarry. In short, the quarry will only elevate the dust and pollution that adjacent land owners have to endure. More importantly, the proposed quarry will directly impact the current agricultural use of our property. Specifically, the quarry will interfere with our ability to receive income from the traditional agricultural operations that have been conducted for generations on the property. And we see no evidence that Marathon or Berry are proposing to compensate us for this lo s s of use and income. For all the reasons discussed in this letter, we are requesting that the Board deny the reque st for the Conditional Use Permit for the Circle Do~ ~ ~ Sincerely, ~ f ~ ~f~ Richard Prather, Lyle Prather, Ned Prather, Don::_~ NOTICE OF FILING APPLICATION RECEIVE:D SEP 1 4 2007 GARFIELD COUNTY BUILOIN G & PLANN ING FOR COLORADO MINED LAND RECLAMATION PERMIT FOR CONSTRUCTION MATERIALS LIMITED IMPACT (110) OPERATION NOTICE TO THE BOARD OF COUNTY COMMISSIONERS GARFIELD COUNTY MARA THON OIL COMPANY (the "Applicant/Operator") has applied for a Construction Materials Limited Impact (110) Reclamation permit from the Colorado Mined Land Reclamation Board (the "Board") to conduct the extraction of construction materials in GARFIELD County . The attached information is being provided to notify you of the location and nature of the proposed operation. The entire application is on file with the Division of Minerals and Geology (the "Division") and the local county clerk and recorder. The applicant/op erator proposes to reclaim the affected land to RANGELAND use. Pursuant to Section 34-32 .5-116( 4 )(m), C.R.S., the Board may confer with the local Board of County Commissioners before approving of the post-mining land use. Accordingly, the Board would appreciate your comments on the proposed operation. Please note that, in order to preserve your right to a hearing before the Board on this application, you must submit written comments on the application within ten (10) days after the date of the applicant's newspaper publication. If you would like to di scuss the proposed post-mining land use, or any other issue regarding this application , please contact the Division of Mineral s and Geology, 1313 Sherman Street, Room 215, Denver, Colorado 80203 , (303) 866-3567 . NOTE TO APPLICANT/OPERA TOR: You MUST attach a copy of the application form to thi s notice . If this is a notice of a change to a previously filed application you mu st either attach a copy of the changes, or attach a complete and accurate description of the change. M:\m in\sh are\vs fonn s\Co ns tructi onl 10 (Approved 05/11/2005)