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HomeMy WebLinkAboutRemonstrator's Presentation 09-27-04 w/attachments u a D u 1J U D o Q o D ID ,ij la o D a o D ~" u u u u u u [.J o D U U U U U U U U U U en CD ::J en en II c: CJ c= ~ ~ CJ c::: CJ c: -== r== Cl EJ ~ -==1 CJ CJ ~ ~ I ss -<as . 1. WRONG Zoning Request . 2. Mining expansion violates public . 3. Relationship of Petitioner to land ow . 4. Underground and surface water . 5. Mining Expansion increases nuisances . 6. Inadequate mining regulation . 7. Inadequate wellhead protection . 8. Illegal expansion of nonconforming uses ~~~~~~~~~~~~~~~~~~~ . WRONG Zoning Request . -- Need MI/Manufacturing District for commercial mining operation, not S l/Residence District . --Description of permitted activities in MI m clearly includes commercial mining . --Performance standards found in MI but none found in S 1 . --Intent of Carmel Common Council ~~~~~~~~~~~~~~~~~~~ ssue #2 ic policy . Mining expansion violates p . -- The Zoning Ordinance is intended to prom public health, safety, comfort, morals, con and general welfare," not the profits of a busI . --The S l/Residence District is intended "to provide development of innovative residential environm keeping with the rural character of this district. . . . --The Ml/Manufacturing District is intended for businesses that have "objectionable factors," includi "noise, glare, dust, odor, smoke or other offensive characteristics. " C~~~~~~~~~~~~~~~~~~ ssue #3 . Relationship of Petition to the land owners. Who owns the surface righ ineral rights, and the mining rights of Muell outh? . --Does the Petitioner own all of the above rig . --If rights are leased, when will they be terminat . --Are the land owner and its owners making the sa commitments and representations as the Petition . --Will the land owner and its owners be able to fulfill a: the commitments being offered by or required of th Petitioner if the Petitioner does not? . -- Is the land owner also in the commercial mining busines . --Will the land owner be liable for Reclamation? ~~~~~~~~~~~~~~~~~~~ . Underground and Surfac Issue #4 . --Mining expansion will increase the per day. . --The total capacity of aquifer serving the PIa reduced by 15%, more during drought con capacity may be needed at a later time. . --Such dewatering will increase the recycling by Pet! groundwater and surface water to the Plant 4 cap by 800,000 gal. per day. . --The recycled water is collected on the ground within the Petitioner's existing stone mine, exposing it to contamination. . -- The Petitioner's own Spill Prevention, Control, and Countermeasure Plan cites to 11 separate locations of hazardous materials without containment facilities. atering by 800,000 gal. wells will be Such ~~~~~~~~~~~~~~~~~~~ ISsue #4 [continued] . --Carmel is being required to for monitoring of its wells that would not be required if Peti . ner did not dewater and recycle the aquifer water. . --The time of travel from Petitioner's pro y to the Plant 4 wellfield is less than one year . --The increased recycling of 800,000 gallons p to the ponds increases Blue Woods Creek runoff to ver and erosion. . -- When Petitioner has completed mining, it will turn pumps, thus eliminating the recycling of groundw help fill the ponds that recharge the aquifer; howev proposed artificial lake will take all of the water fio out of the Plant 4 aquifer, making recharging of the a problematic. . --Petitioner does not own Mueller South and may not own t11 land under the ponds at Gray Road and 106th Street. Therefore, control of the surface water after the end of th Petitioner's leasehold rights is not going to revert to the City of Carmel but needs to be controlled. lOlaWJeo !. 1; ~ ' Jl rc /(~- ., / ) ......./ 0 ~,\ \ ,. 'I I' .. . . -.... q~r~. ' .". -\. -.' . . .'\'~. .'. ' : t ~ I ., cy t.,' ,"'t \.. J' ~ "c' , '(.rl.- . .. I.. ~ · " "'41' III. 1:. r \ L I~ ~~' In;' '= :/) '\( ...,..." . ,,'''''''' .- /-," . "'-:,1 i ..'(! I , .' ,II .\I! .. tr:\\. , ~\) . '" \~ -.:."" . . , ... ~..,'~- . , ,.. .._r fI!." ....... t' J -~ .-. ....1 , :. ", '. ,. I... I" , I.. 'r-j' .. . ~ . I II ..' " . . ,.t II. . t.. . '~..,' "\ r :. t~ · ., f I , . ',I I 111.'~\lr.:, t , ..1 I.. " I,' I' << . ~ I.. ' " [I i" I ~'--~ ~ II I,'" 11:.";;'l," "t L .. ." "1' ~:I. . , ~.' I , 'il l. I I II.. "I ' '!," r I' I' , I · ,.. "'r II' "I I f '.::-,.. i: :/' . , II '1 I It""(;# :/ ... '. " 'I\: :.,... I... , 1(- 'I ,~J )J. c; r= c c--: c::: C c-: C=C' c-. C' c: C: C' CJ c; c=: ~ ~. e#5 . Mining Expansion Increases ances, including: . -- Noise: Trucks, earthmoving equipm loading equipment, increased use of Carmel Sa nt . -- Fugitive Dust and Dirt from operations and tracking dirt onto the streets . -- Excessive Truck Traffic and Road Repair on Gra 106th St., and Hazel Dell Parkway . -- Unreasonable Hours of Operation from 6 AM to 10 at minimum . -- Blasting: Noise, vibration, dust, and flyrock are all elements of blasting, if allowed to occur in the future. ~~~L;~C~C~~~~~~~~~~~ . Inadequate mining regulat! inadequate commitments . --There is no Mining Ordinance, Statute, or La regulates mining activity of the Petitioner in . --It is not feasible, through neighborhood or local commitments adopted by private agreement, a B or an APC, to adopt comprehensive regulations 0 business operation that involves dangerous activity . -- The brief and self-serving commitments offered by the Petitioner do not provide any real and enforceable protection for Carmel or its citizens. c=: C1 C: L ] C 0 C; C~ C' C=' t=) c= C; C' .-----~ '---l .-----, ------i ..----. , ~ IL..---! .~ ~, ____, ,,------J ssue #7 . Inadequate wellhead protec · inadequate commitments . --The current Wellhead Protection Ordinanc agreed to be inadequate to regulate the cu situation and is being studied for major revi . --It is not feasible to adopt comprehensive regulatio the protection of wellheads through neighborho local commitments adopted by private agreement, BZA, or an APe. . --The commitments offered by the Petitioner contain nothing about future monitoring, pumping, or other matters involving Plant 4 and provide no protection for Carmel or its citizens. . IS c; EJ C~: I J C 0 C: C C' C,' C) c= c: ,c: C! C-:l C! CJ CJ Ssue #8 . Illegal expansion of exis · uses on adjoining lands . --Petitioner will use the Indianapolis Nort ponds on the west side of Gray Road to recycle the groundwater from Mueller So . --Petitioner will use the Carmel Sand Plant for pr the aggregate from Mueller South. . --Petitioner will use off-site roadways to access publ! roads for its trucks to reach the Carmel Sand plan . -- Each of these properties is a nonconforming use that cannot be changed without a variance or special use approval by this BZA. . --None of the above properties are included in this Application, so it cannot be approved as submitted. nonconforming nt and the . and 0 0 u 0 U en c u 0 -- U en -- U u (]) [J 0 u (]) en U ::J 0 co U -- u 0 (]) c. u en u u u u c: ~ c: ~ C l~ Cl ~ C C' ~ ~ ~ e: G~ C' ~ ~ pecial Use Decisions The particular physica .tability of the premises in question for the proposed Sial Use. The economic factors related to roposed Special Use, such as cost/benefit to the co ity and its anticipated effect on surrounding prop values. The social/neighborhood factors related t proposed Special Use, such as compatibili existing uses and those permitted under curre in the vicinity of the premises under consideratl how the proposed Special Use will effect neighborhood integrity. The adequacy and availability of water, sewage and storm drainage facilities and police and fire protection. The effects of the proposed Special Use on vehicular and pedestrian traffic in and around the premises upon which the Special Use is proposed. Factors in . 1. . 2. . 3. . 4. . 5. C~~~~~!~l,]~~~~~~n~~~~ SpeCI8 ~se Decision #1 : The premises are n~}!Sically suitable for the proposed special u'Se ecause of . Dewatering of the aquifer; . Adverse effects on storm water manageme . Potential wellfield contamination; and . Removal of hundreds of mature trees and natural buffer. c: c:: C: Cl c= '-.-,! c) CJ L:J C=' c:: C:~= ~.. C CJ a::::::: c: E: Ci Speci 1~se Decision #2: and surrounding prop rt values far outweigh the alleged benefi ecause of: . Increased road maintenance for Carme , . Increased Carmel Utilities capital expendi . Increased monitoring costs and contaminatio . Negative impact on property values; . Increased risk of subsidence; . Potential for more open pit blasting; and . De minimus offsetting tax increases. ~~~~~~~~~~~~~~o~~~~ Special s ecision #3: Expansion of Commercia ining is inherently incompatible with expensiv "ngle-family residential housing and will neighborhood integrity becau . Extensive hours of operation: 6 AM to lOP longer; . Increased risks to neighbors from truck traffic; . Increased noise and dust; . Attractive nuisance for children; . Increased potential for blasting; CJ t=) C; ~ C=' 1-,. CJ C~ e::; c: CJ .c=; CjCi C-=-:J CJ c:J C,~ CJ Special s J)ecision #3: [conti~J . Increased risk of injury from flyroc subsidence; and . No neighbor should have the right to con another neighbor's property, but Petitio suggests that all other uses should keep t11 distance and history shows that such distan is perhaps 1500 feet. Such setbacks destroy neighborhoods rather than building neighborhood integrity. A Commercial Mine does not belong here. CJ Cl C; CJ .C.: c: CJ CJ C: c:: Cj Cl c=J L -; C-) ~ C--: E: c: Speci l-Use Decision #4: of groundwater for use Carmel and its Citizens by . Decreasing the groundwater available Utilities Plant 4 by approximately 800,0 per day, which results in: . -- Decreased yield of Carmel wells, . -- Increased risk of contamination of aquifer, an . --Increased monitoring costs for 50+ years; and . --Increased storm water management caused by pumping 800,000 gpd of additional groundwater into ponds emptying into Blue Woods Creek. CJ CJ C: CjC i. c; Cl CJ C} C~ I ,.; CJ r::::J. Cl t:::::::J c: C: t:=: C' Specia "Use Decision #5: The proposed use ~'h~ve negative effects on vehicular and pedestna traffic in and around the premises be se of: . Increased Truck Noise; . Increased traffic hazards on 106th Street an Hazel Dell and at their intersections; . Increased dust and debris tracked onto public roads; and . If Gray Road is used, then truck traffic willlikel destroy the new Roundabout at 106th and Gra Rd. by cutting the comers. o !U o I I I Lt {] '0 o o 'U U D o I I I 10 o u o u o ID ~ Q) c::: ~'DC::'C::~t= ceLL' , . ' C; , .~. ,~~ c-: t:=.=: ~,> {::: L' <<:=:, t=:J C=' r:;: c~ Rebuttals . 1. The Neighborhood A sis tendered by Petitioner is irrelevant and inco usive . 2. The Sound Level Assessment t ered by Petitioner is incomplete . 3. Petitioner's objections to Remonstrato mphasis on the hazards of blasting are disinge . 4. Petitioner's objection to the incorporation 0 written materials," into the record ofp by Remonstrators is not well founded. . 5. The Law does not favor Special Uses until they s criteria for approval. . 6. The Petitioner has not provided evidence sufficient t prove each of the five Special Use factors. . 7. Petitioner's proposed Commitments are grossly inadeq when laws do not exist to control behavior. ~~~~~~~~t~~~~~c~~~~ ,.. . The Neighborhood Analy. tendered by Petitioner is Irrelevant and Inconclusive . --Petitioner's neighborhood analyzer do not address the central question of whether or not the commercial mine on Mueller South wou property values in the future. . --The Neighborhood Analysis uses obsolete data. . --The days on market for Kingswood in 2002 are m twice the average of the "competing subdivision . --The sales and listing data for Kingswood are almost a the west side of Kingswood, one-half mile from the Carmel Sand plant. . -- The resale on the east side of Kingswood shows an increase in value of only 1.17 percent per year, less than one-third of the rate for properties on the west sid of Kingswood. r=J c:! CJ t=l r:=:J ~ c=;J D c:::;j d CJ Cl r::::=; ~ c .. '. ..... ..' ';Kingswood CM4 .... ..,..,,:,, CMA: -Number of Properties Low High Average List/Sale Price/sq.ft. Avg.DQM Active Listings - 3 $299,900 $369,900 $343,233 $90.00 4~ Pending Sales -2 $279,900 $305,000 $292,450 $110.00 20 Sales 2000 - 24 $248.000 $355.000 $287.833 $94.00 53 Sales 2001 . 12 $281 ,500 $344,000 5312,837 $93.00 31 Sales 2002 - 1 2 $267,000 $334,000 5298,875 $101.00 91 \IV . .... dfi Id 'CMA . ..;" . ~.:. ; .::::;.. . ... . .....- . . - '., ....... '.,,, .q,p. .,e .;;;, ". . '. "',;;" CMA: -Number of Properties Low High Average LisVSale Price/sq.: AI/g. DOM Active listings - 5 $384.900 $549,900 $444.900 $94.00 67 Pending Sales -1 $419.900 $419,900 $419,900 $83.00 215 Sales 2000 - 6 $300,500 $495,000 $357,983 $88.00 109 Sales 2001 - 7 5305,000 $493,000 $396,914 $99.00 79 Sales 2002 - 18 5407,500 $550,000 $431.257 $101.00 48 o r=J c:J CJ o D Q o o o D o D Q u 0' Q Ill' .. ~ o ~ D D , t, ~. Ii 'f' Iil .",~ .~ ,~ :3 ~ ll~ "J z ~.,<, ti'..3 :;;: ~l ~':; ~ ~ ~,~ 1\ ~ r ri ~ ~ "Iw" r~, ~ 1 t ~, a Q ;<-,l;}t' Q o o ~ ~ D ~ I i a 0 ~-; :~ a .~ Q 0 ~ ~~ a t i't~ ~~,'}' i-?' ~:"~~ i,i',' " I'tl ~ ~ ~lff!; 'it ~~~~~~~~~~~~~~~~~~~ . The Sound Level Assess nt tendered by Petitioner is Incomplete . --Includes a berm that does not exist a .s not proposed. . --Does not show the "spikes" of noise, su beepers and truck dumping, only ten-m averages. . --Does not show the percentage of capacity ofth Sand plant being used at the time of measure . -- Measurements were taken during a cicada infestati No measurements were taken at any second floo . . --Shows that occasionally the Carmel Sand plant doubl the actual noise for Kingswood. . --Shows that dump trucks generate 100db, front-end loaders generate 110 db, and the Carmel Sand plant generates 70 db. I' o ~ Q r- ~ I I ~ _.._~ ~ ~ 1:1. "~I". .. i, Q ~~.... _",--,.i-;. 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A},d _.11.1(1 1:: ---~. ....- .." , ,. -- - '. - '::--1 I I ~ Ii :;- '-.... ~ .. --I D ~ ~ I I [ f~ o D a D CJ r=J CJ r:=J EJ EJ CJ CJ EJ EJ r:=J EJ r:=J TABLE 3.1 AMBIENT MEASUREMENT SUMMARY r -.--. .--.r~~-T-...-.- ~.~~~~~'~~MSE~~Nst~~:~~-'--l I LOCATION 1 SITE 1.0. I (leq [10 MINUTES1IN dB~___...._1 1':ll I PLANT I PLANT NOT ! ! __ i OPERATING. I ~_ o.~_ER~T1~9__J :- I~f:i:d ;;- i ~0:;i rap of I)crm wost 01 eMmel ---B~~~;'~1-" GO :;"'.:;7 Sand Plant __..____ Belrn 5 t., ,-'I ~/l-:i7 [301 rn {i 6~ t~4.t~7 r==~~..~:I~~~_ ____._ ,~...--.._---- ..--~.~~t:.;;:;:~.....I---...-:;. :\ I=.~~!!ii:~~~:; 7 r.~.e!::~1 55 Behind bUIITI west of sand I Berm 1 I :i8 and !Jrav<:l uperatlon L.-.--..-....--- Berm 12 :,:~ .S7 ~tt.-S7 G:l.S7 n ~~~~~;.; .. _ _.. "._ j I Fropc):;ccJ EXlJilnsion I t;4 S-1.:;7 . ------............ ....---.....---1--...---- 55 I :;.1.r,7 r\e:~"" -----00.59---. "T'''''' :;"'-57 .......,.---------.-.- T I . XP1 48 I 'l'i-~;D I 1'-"'''-'---' i:::;~p. :; i;;;;==i :::-- ::==~~.=-T~~;;--I BK2 1\7 47.50 nellll I:i "'---...--..---.-- BK3 51 i ----.--.... ~I___...\_ ''':..',~.'''''---'''-~......... '17-:;0 i _..-J.... ~~~ ! l .:7.50__. IINote: -. . ll~_ ."_ _ .__ ~i~~_~~~_ i_:!,~_~~.~::_"ced ()"/ Cia.~:~~.~~;;;-i-~o~:.:.~"l.U~~-~l~.-~.:-~~-:.~~.~ll?n Ar::~..____.__ ~:~ .,_.__~_~_.. __: Kin9SW()()d Subdivision '11.50 . <J.. t=J EJ ~ CJ r=::J r:=J - r== r== ~ c=. ~ ,.----. ~ ~ ~, r--r .----" .----r, .----, .---' .----r ------ ~ ~ ~ ----- ------.; ------ -------..J ------ ______ ------.; C::' c= C=' l:==' . Petitioner's objections to monstrators' emphasis on the hazards of blasting is disl enuous because: buttal #3 . --Petitioner's Application for Surface Bla . withdrawn; . --Petitioner's Application for Underground Bla withdrawn; . --The Remonstrators suffer the effects of the existin . --Blasting on Mueller South will bring noise and pote flyrock and vibration damage to 106th Street, Haze Parkway, Carmelot Park, and the homes located at 1 St. and Hazel Dell Parkway, and 1500 feet closer to Kingswood residences; and . --No Commitment is proposed to prohibit blasting for all ti . -- Therefore, Remonstrators believe that Petitioner intends to seek permission to blast at Mueller South 25 more years D a .. * "4" ~~V' .: .. ~ ................ .,. .............:............. -:: : ' ............. ; ...... .." .. ..... ... ~, ':::::::::~ J" .. p. ~: .........- ....: , . , : : '..' .....,...... ... " ~ t " : "'..,......."~ : : t ..,..,~#"''' , ...........~*......9.......'.............~ .'" 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' :J Q f'f.""- Q ~~~~~~~~~~~~~~~~~~~ · Petitioner's objection to the. orporation of "all such written materials," into the reco of proceedings by Remonstrators is not well founded ause: . --The BZA is not a trial court and is not boun the Rules of Evidence; . --The BZA ruled that it would not restrict evidenc became repetitive; . --The BZA is to weigh all evidence to determine if it s the basis for a decision; . --The Petitioner does not demonstrate in what way the ma submitted to the record by the Remonstrators are supp to be improper within the above standard, thereby wai such objections; and . -- The Petitioner has done exactly the same thing. ~~~~~~~~L1~~~~~~~~~~ Rebu tal #5 . The Law does not favor Special U until the Petitioner satisfies all criteri approval, which the Petitioner has not . --All zoning is local and local ordinances control ca from other jurisdictions. . --This Application seeks a commercial mine in an S 1 district rather than in an M 1 district. . --Being a commercial mine in an SI district, its use is "obviously inappropriate as a result of special and unique conditions" and should be denied, per Carmel City Code Section 21.01. LJ C~ c: CJ t::= c CJ t:=J L 1 .---: ~ .---; ~ ------~L--~c;LJt=:t==CJc= uttal #6 . The Petitioner has not pro · ed evidence sufficient to prove each of the e Special Use criteria necessary for approval. . --The burden of proof rests with the Petitio . --Each of the five criteria listed in Carmel Co Use approval must be satisfied before any Application approval arises . --Mere argument does not substitute for evidence . --Dewatering City wells, adding 64 dump truck trips hour along Hazel Dell, cutting down hundreds of mature trees, enlarging a commercial mine by almo 100 acres, "reclamation" in the form of an unusable open pit 30 feet deep, and clearing the way for future blasting, cannot be viewed favorably. ~~~~~c~~~~~~~~~~~~~ Rebu tal #7 · Petitioner's recently-proposed mitrnents are grossly inadequate when laws do n control behavior. . --Carmel has no ordinance, Indiana has no statute, there is no federal law regulating commercial r . . mInIng. . --If commitments are intended to be a substitute for suc laws, then they must be as comprehensive as the la · --The proposed commitments make no attempt at being a substitute for governmental regulation and leave the Petitioner essentially free to operate at will. ~~~~~~~~~~~~~~~~~~~ . Examples of Omitted Com etments: . --No commitment against all future sting, so, door open . --No commitment to adhere to MI perfo ce standards . --No commitment of joint and severalliabili he land owners, so loss of Lease could be loss of liability . --No true restriction on hours of operation, noise, d traffic . --No commitment that Blue Woods creek will be reloc and the berms will be built before mining commenc . --No commitment to reclaim the land for future beneficial use, such as a Park . --No commitment submitting to a special regulatory scheme or jurisdiction of a mining commission __.--J [~L~~~~~~~~~~~~~~~~~~ . --No commitments for plan review, appr 1, monitoring, or modification . --No commitment for a meaningful penalty fo the commitments, the mining plan, or other regulations . --No commitments regarding groundwater, recyclin monitoring, or reimbursements to Carmel . --No commitments regarding the amount, disbursemen release, or management of the financial security guarantying the reclamation plan . --No commitment allowing neighbors to enforce the commitments u u u o u u o u o u o o u u o u u o u ...... (.) CO LL '+- o C/) en ~ - ~ c=; C~, c=: CJ ( ;. r= CJ c: C=. E:)" c; CJ c=. c: C). c= c:; c: Findin ~f Fact #1 : · Floodplain rule applies · --Petitioner does not have all permits an support documents from third parties in to meet requirements of Carmel City Code, · --Therefore, BZA does not have jurisdiction t hear this Application at this time. ~~~~OD~~~~~~~~~~~~~ tna~ng of Fact #2 . The commercial mine is not consis character of the district because the ci comprehensive plan does not include co mining in low-intensity districts and . --It is not low intensity . --It is incompatible with residential housing . --Generates considerable traffic and noise . --Does not conform to development standards . --High intensity industrial use . --Should be Ml zoning ~~~~~~~~~~~~~~~~~~~ Finding f Fact #3: . The Land in question is not ph suitable because: . --The use will be detrimental to the aquI reducing the wellfield capacity by 15% a Carmel Utilities Plant 4. . --The land is currently heavily wooded, all of which will be destroyed by the proposed use. ~~~~~~~~(~~~~~~~~~~~ · Effects on adjacent Ian property values will be detrimental because · --Increased noise and dust for several y · --Increased heavy truck traffic for a numb years . --Increased road repair costs to City · --Increased traffic hazards of gravel trucks on residential roads · --Increased use of illegal Carmel sand and gravel plant D~~~~~~~(l~~~~~~~~~~ Findin f~~ct #4: [continued] . --Decreased capacity of the Carmelot . --Increased risk of wellfield contaminati . --Increased risk of subsidence from dewate . --Approval will harm property values . --Unreasonable hours of operation, being virtu~ unlimited after the overburden is removed. ~~~~~~~~~~qC~~I~~~~~~ Findin ~f Fact #5: . Vehicular and pedestrian t fic flow, availability of water sewage 0 torm drainage facilities and police an protection will be adversely affecte of . --Increased heavy truck traffic-Unsafe risk to Citizens . --Increased road damage-Cost to Carmel . --Decreased yield of Carmel wells-Cost to Carm . --Increased risk of contamination of aquifer-Risk to Citizens; Cost to Carmel ~~~~~~)~~~~o~~~~~~~~ Sum ary . 1. WRONG Zoning Request . 2. Mining expansion violates public . 3. Relationship of Petitioner to land ow . 4. Underground and surface water . 5. Mining Expansion increases nuisances . 6. Inadequate mining regulation . 7. Inadequate wellhead protection . 8. Illegal expansion of nonconforming uses [10c~~~~~rl~d~~~~~~~~ mendations The Remonstrator ~st that the members of the BZ te to: . ADOPT the Special Use Decisions set above. . DENY the Application by Petition , .- YARGER ENGlNEr1llNG SpedaliziJ/g In TrqfJic EJ/gineering 1 Cor. 10:31 ... whateL'er YOll do, do it all for the glo!)' of Cod i/t~~ Mr. Philip C. Thrasher Thrasher Buschmann Griffith & Voelkel, PC 151 North Delaware Street Indianapolis, Indiana 46204 September 27,2004 Re: Sand and Gravel South Mueller Martin Marietta Aggregates Mining Operation 106th Street at Hazel Dell Parkway Carmel, Indiana Yarger Engineering Job Number: 20040401 Dear Mr. Thrasher, On Friday, May 7, 2004 and Wednesday, August 11,2004, I examined the Carmel Department of Community Services files for this project. While the files were quite large, there was little actual information on traffic. Most of the comments on traffic were general without specific data or studies to backup the comments. I also visited the roads surrounding the site. I have the following comments about the petition. 1. From our discussions today, I understand that Martin Marietta's sound study indicated that there will be 32 round trip per hour from the Carmel Concrete driveway on Gray Road. It is unclear if this represents all of their traffic, or only the gravel trucks. It also does not break down the traffic by hour since some hours will have more traffic than the average while others have less traffic. I assume it is only the truck traffic since the peak hours would contain workers coming and leaving their jobs. We also need to know how many of the existing trips will continue and how many new trips there will be from other driveways. 2. The City of Carmel's Transportation Impact Studies for Proposed Developments Applicant's Guide says a traffic impact study may be requested if there will be more than 100 peak hour trips in the peak direction. I believe that this could be the case and an estimate is needed. Even if they do not meet the 100 trips, a traffic operations analysis may be requested for a driveway to any frontage road, arterial or collector street. A transportation impact study should define how much traffic would use each of Martin Marietta's driveways, Gray Road, 96th Street, 106th Street and Hazel Dell Parkway. 3. Martin Marietta requested the vacation of River Road, but said in May that they will continue its use as an access point. I assume they mean that they will use the vacated River Road to access I06th Street. It was unclear how much of their operation will depend on this access point or travel on I06th Street. In August I found references that indicated that their truck traffic will use the existing Carmel Concrete driveway to Gray Road and not use River Road to access 106th Street. Either way, this information should be documented in a transportation impact study. Their plan to use the River Road to access 106th Street qualifies for a traffic operations analysis even if it is not going to be used for trucks. 4. The study should consider the level of service impacts on all of the major roads listed in item 2 and their intersections for the morning and afternoon peak hours. It should also include an appropriate horizon year of at least 10 to 20 years out to incorporate the development of the surrounding areas. Heavily loaded trucks do not respond in traffic the same way that passenger cars do, therefore, the study should specifically address the differences between cars and fully loaded dump trucks. 1401 Alim.ingo Drive Indianapolis, Indiana 46260-4058 Voiee 317-475-1100 Fax 317.475.0100 Mr. Thrasher September 27, 2004 Page 2 5. I am concerned about the use of 106th Street as a heavy vehicle route if their trucks will then travel on Hazel Dell Parkway. Turns for dump trucks should be checked at this location for intersection sight distance. Dump trucks require significantly larger gaps in traffic to turn than passenger cars. The median does not appear to be large enough for a dump truck to make a left turn by first crossing the southbound lanes and waiting in the median for a northbound gap, therefore, the gap in traffic must be in both directions for left turns. If there is insufficient capacity or sight distance at the intersection of Hazel Dell Parkway and 106th Street, then there could be a resulting safety issue. I also did a quick check of the speeds on Hazel Dell Parkway. Even though the posted speed limit is 40 MPH, the 50th percentile speed appears to be over 50 MPH. A traffic impact study should include a detailed speed study to determine the proper gap for trucks for the intersection sight distance and capacity analyses. Typically the speed used in a sight distance analysis would be the 85th percentile speed. I only checked for the approximate 50th percentile speed. I would not be surprised if the 85th percentile speed was over 55 MPH. 6. I am also concerned about the 106th Street pavement's ability to withstand a large amount of truck traffic. Pavement cores with soil samples of the subgrade should be analyzed before allowing additional trucks on 106th Street. If the pavement is inadequate, Martin Marietta should upgrade it. The use of the driveway at the vacated River Road to access 106th would actually be less detrimental to the 106th Street pavement since less pavement length would be exposed to the trucks than if they use the Gray Road driveway and then travel the entire length between Gray Road and Hazel Dell Parkway. 7. The pavement designs of Hazel Dell Parkway and Gray Road should be researched to determine if Martin Marietta's truck traffic has been included in the calculations. While some truck traffic probably was included, the actual heavy truck volume is particularly important in determining the appropriate pavement design. Heavy vehicle traffic, soil strength, and weather are the main factors in designing pavements. On heavy vehicle routes, passenger car volumes have little impact on the pavement design. 8. In the documents supplied by Martin Marietta, they mention the reduction of trucks coming from Noblesville. No where did I see a connection between this matter and the closing of the Noblesville facility. Regardless, the routes involved for the Noblesville operation to use the facilities north of 106th do not involve 106th Street, Gray Road, or Hazel Dell Parkway south of 106th Street. To tie any decrease from Noblesville to this discussion is to "mix apples and oranges," so to speak. It is my opinion that the petitioner should provide a full transportation impact study to address the issues listed above, and that the Board of Zoning Appeals should not approve this petition without the additional information. I have attached my qualifications for your use. If you have any questions or comments, please call me at 317-475-1100. Sincerely, Yarger Engineering, Inc. -tJ-LyA/L ~ Bradley William Yarger, P.E.; P.T.O.E. President BWYlbwy Attachments: Biographical Data for Bradley William Yarger "., YARGER I ENGINEmING Specializi1/g In TrofJk E1/gi~ 1 Cor. 10:31 ...whateveryoll do, do it 0/1 for the glory of God Bradley William Yarger, PE, P.T.O.E PROFESSIONAL EXPERIENCE July 1995 to Present President / Owner Yarger Engineering, Inc., Indianapolis, Indiana Experience: . Ameriplex Development Traffic Study, Indianapolis, Indiana . CMAQ Study, Lynhurst Drive, High School Road, Girls School Road, Indianapolis, Indiana . Kohl's Traffic Impact Study, Warsaw, IN . McKinley A venue Remonstration, Muncie, Indiana · Petro Planned Unit Development, Traffic Impact Study and Roadway Design, Warsaw, Indiana Traffic Impact Study, Westfield Washington Schools, Westfield, Indiana · US 31 at American Legion Traffic Control Design and Construction Engineering, Greenwood, Indiana . College Avenue at l06th Street Remonstration, Clay Township, Carmel, IN . Parkwood West Remonstration, 1-465 at US 31 North Junction, Hamilton County for Heartland Coalition Towne Road at l06th St. Remonstration, Hamilton Co., Indiana . Traffic Study, Roadway Design and Construction Engineering, University High School, Carmel, Indiana . Clay West Transportation and Land Use Plan, Carmel, Indiana (Privately Funded) . Johnson Street Signal Timings, Elkhart, Indiana . Hart Street Signal Timings, Vincennes, Indiana . SR 1 Progression Study, Fort Wayne, Indiana . Traffic Signal Operational Review, Elkhart, Indiana . INDOT Statewide Traffic Data Collection . On-Call Traffic Engineering Services, Vincennes, Indiana . Village of West Clay Remonstration, Hamilton County . Various Traffic Impact Studies . Various Traffic Impact Study Remonstrations . Various Governmental Project Promotions & Remonstrations, Private Clients . Various Traffic Signal Designs July 1994 to June 1995 Transportation Project Manager Schneider Engineering Corporation, Danville, Indiana Experience: . Eli Lilly Roadway and Site Design . Nordyke Street Design, Indianapolis . 38th Street and Meadows Drive Design, Indianapolis . Comprehensive Plan, Pendleton . Wal-Mart Traffic Studies and Signal Designs, Terre Haute and Franklin . Westfield Washington High School Traffic Study 1401 Alimingo Drive Indianapolis, Indiana 46260-4058 Voiee 317.475-1100 Fax 317.475-0100 YARGER~ ENGJNmUNG Specro/izing In Traffic Engineering Bradley William Yarger, PE, P.T.O.E PROFESSIONAL EXPERIENCE (Continued) June 1994 to July 1994 Owner / President Yarger Engineering, Indianapolis, Indiana Experience: July 1987 to April 1994 Experience: Jan. 1987 to June 1987 Experience: Nov. 1984 to Dec. 1986 Experience: June 1983 to Nov. 1984 Experience: 1401 Alimingo Drive · Sagamore Park Traffic Impact Study, Merrillville, Indiana Project Manager / Engineer HNTB Corporation, Indianapolis, Indiana · West Sixteenth Street Signal System, Indianapolis · Lafayette Railroad Relocation Project · 1-70 4R Reconstruction Project · Fifth Street Reconstruction Project, Lafayette . Borman Freeway Management Study, Lake County · Holiday Development Freeway Analysis, Marion Co. · INDOT Traffic Signal Design Project . Numerous Traffic Impact Analyses · Eli Lilly and Company Master Plan . Indianapolis International Airport Master Plan . Zionsville Transportation Thoroughfare Plan . Carmel - Clay Comprehensive Plan Update Transportation Engineer Bergmann Associates, Rochester, New York . Traffic Impact Analyses . Traffic Signal System Timing . Traffic Signal Design . Roadway Lighting Design . Community Master Planning District Traffic Development Engineer Indiana Department of Highways Crawfordsville, Indiana . Traffic Signal Design, Operation, & Construction . Signage Design And Construction . Project Programming . Roadway Lighting Design And Construction . 3R Roadway Design And Construction . Intersection Design And Construction · District Traffic Division Liaison To Design And Construction District Traffic Safety Engineer Indiana Department of Highways Crawfordsville, Indiana . Accident Studies . Driveway Permit Review . Municipal Traffic Engineering Assistance . Guardrail Design Indianapolis, Indiana 4626O-40S8 Voiee 317-475-1100 1 Cor. 10:31 ... whatel'er YOll do, do it all for the glary of God Fax 317.475.0100 YARGERtl r~GJNE}lDNG SpecializiJ/g In 7inffic El/gilleenllg 1 Cor. 10:31 ...whatever you do, do it aI/for the glory' of God. Bradley William Yarger, PE, P.T.O.E PROFESSIONAL REGISTRATION AND EDUCATION Professional Traffic Operations Engineer, Institute of Transportation Engineers, 2003 Professional Engineer, Indiana 1988 Bachelor of Science, Civil Engineering, 1983 Purdue University, West Lafayette, Indiana Major: Transportation Engineering ADDITIONAL TRAINING International Signal Manufacturers' Association Certification Traffic Signals Level 2, 2004 ITE Professional Traffic Operations Engineer Exam Review Seminar 2003 TSIS Seminar, MCTrans Center, 2002 International Signal Manufacturers' Association Certification Traffic Signals Levell, 2000 International Signal Manufacturers' Association Certification Work Zones, 1999 Annual Purdue Road School, 1984 - 1992, 1998, 1999, 2000 Indiana Section ofITE Traffic Seminars, 1989 - 93, 1996, 1997, 1999 SBA - SCORE - Ivy Tech, Small Business Workshop, 1996 Business Matters' Small Business Management, 1995 Lincoln Land Institute Short Course, 1994 ITE International Meetings, 1986, 1990, 1991, 1993 ASCE Applications on Advanced Technologies Conference, 1991 Traffic Signal Design Conference, 1986 Rural Highway and Urban Street Capacity Seminar, 1986 Freeway Traffic Management Seminar, 1985 Routine Maintenance of Traffic Signal Seminar, 1984 The Use of the Traffic Control Devices Handbook Seminar, 1984 PROFESSIONAL AFFILIATIONS Institute of Transportation Engineers Member: International, District III, Indiana Section Past Chairman, Traffic 91 Seminar Committee Past Member, Traffic 90 Seminar Committee Past District Director International Municipal Signal Association Associate Member RELATED EXPERIENCE Speaker Highway Capacity Manual and Software ITE Traffic 99 Seminar, July 99 ITE Traffic 96 Seminar, July 96 ITE Traffic 90 Seminar, June 90 Fully Actuated vs. Semi-Actuated Traffic Signal Systems, ITE International Meeting, Sept. 1993 HNTB Seminar, October 1993 ITE District III Meeting, Sept. 1995 TRANSYT-7F Training Seminars, Spring 1986 Microcomputers Users, Purdue Road School, March 1986 Signal Operations, Purdue Road School, March 1986 Computerized Traffic Analysis using NETSIM ITE Joint Indiana Section -- Purdue Student Chapter Meeting, Spring 1983 Author Instructor Panelist Speaker Speaker 1401 AIimingo Drive Indianapolis, Indiana 46260-4058 Voiee 317-475-noo Fax 317-475-0100 ...' \'" .. YARGER I ENGlNffiRlNG Specializing In Traffit; Engineering 1 Cor. 10:31 ". whatever you da, do it all for tIle glory of Cod. Bradley William Yarger, PE, P.T.O.E LIST OF REFERENCES Client: Pam Lambert Treasurer Heartland Coalition 616 Copley Place Indianapolis, Indiana 46290 317-844-5511 317-566-8909 Weekends David L. Palenchar Traffic Supervisor Public Works and Utilities City of Elkhart 619 S. Fifth Street Elkhart, Indiana 46516 219-522-2884 elkharttraffic@juno.com - preferred contact method Carl (Bud) Wilson BOCAR 1542 Greyhound Pass Cannel, Indiana 46032 317-587-1460 Charles Webster University High School 2825 West 116th Street Cannel, Indianapolis 46032 317-733-4475 Brain Shapiro Shapiro's Deli 808 South Meridian Street Indianapolis, Indiana 46024 317-631-4041 1401 AIimingo Drive Indianapolis, Indiana 46260.4058 Thomas Whitsitt Attorney at Law Giddins, Whitsitt, and McClure 121 North Meridian Street Post Office Box 663 Lebanon, Indiana 46052 765-482-6632 Professional: Randy Phegley, P.E. District Traffic Investigations Engineer Vincennes District Indiana Department of Transportation Post Office Box 376 Vincennes, Indiana 47591 812-882-8330 Kamyar Fattahi, P. E. Traffic Engineering Consultants Post Office Box 6760 South Bend, Indiana 46660 219-271-1002 Personal: William Derrer President TEQ Solutions 1811 Executive Drive, Suite S Indianapolis, Indiana 46241 317-227-2610 Tamantha Stevens Attorney at Law Stevens and Associates 3755 East 82nd Street Indianapolis, Indiana 46240 317-915-9900 Voiee 317.475.1100 Fax 317.475.0100 .." ~~ ,~ --- ... STATE OF INDIANA CARMEL/CLAY ADVISORY BOARD OF ZONING APPEALS ~ DOCKET NO. 04040024 I I ~ b . COUNTY OF HAMILTON In re Application for Special Use Approval for Sand and Gravel Operation on 96.921 acres (Mueller South) REMONSTRATORS' OBJECTIONS TO AFFIDAVIT OF MICHAEL C. LADY AND ATTACHED NEIGHBORHOOD ANALYSIS COME NOW William D. McEvoy, Larry J. Kane, Greg Policka, Rex Weiper, Phil Kincaid, and Kingswood Homeowners Association, Inc. (collectively, the "Remonstrators"), by counsel, and object to the admission into the record of the Affidavit (the "Affidavit") of Michael C. Lady (the "Affiant") dated August 11, 2004 and the Neighborhood Analysis Kingswood Subdivision dated January 30, 2003 attached thereto (the "Neighborhood Analysis"), and in support thereof state the following reasons: 1. Paragraph 2 of the Affidavit states that the Affiant prepared the Neighborhood Analysis, but the Neighborhood Analysis states that it was prepared by two individuals. There is no description of the amount or nature of the involvement in the preparation of the Neighborhood Analysis by either individual. 2. The Neighborhood Analysis is not an appraisal of any home or group of properties, but rather a simple summary of selling and listing prices during 2000-2002. 3. The stated purpose of the Neighborhood Analysis is "to determine if external factors have had a negative impact on the marketability and value of properties" within Kingswood; however, the Affiant did not interview any individuals, such as real estate brokers, buyers, or sellers of homes within Kingswood, to find out whether or not the existence of the Martin Marietta operations has any impact on prices or if it had any impact on their buying or selling decisions. 4. Inasmuch as the decision to buy or sell a home is complicated with dozens of separate factors, it is unreasonable to state from simple sales and listing price histories that there was no adverse effect from any particular external factor, such as mining, schools, shopping, access to downtown, or churches. 5. The Neighborhood Analysis is not intended to predict the effect on Kingswood of the proposed expansion of the mining onto Mueller South and does not attempt to do so; therefore, it is irrelevant to the question of whether or not the mining expansion on Mueller South will have any impact on Kingswood. 6. Remonstrators object to all of paragraph 4 of the Affidavit as being hearsay from representatives of the Petitioner, Martin Marietta Materials, Inc., and because it reaches 1 c ... conclusions that are not based on any facts stated in the Neighborhood Analysis or included in the Application of the Petitioner. 7. Remonstrators object to all of paragraph 5 of the Affidavit as being irrelevant. There is no connection between the value of a new home located on a peaceful lake in Marion County and a smaller, older home located in Kingswood. Further, Remonstrators do not believe that the home in question is located "adjacent to an active stone mining operation," but rather is located on an abandoned gravel pit that has now filled with water and is available for the occupant's recreational use. 8. Remonstrators object to all of paragraph 6 of the Affidavit as incorporating information allegedly reviewed by the Affiant but not included in the Neighborhood Analysis, thereby eluding review. Such comments should not be given any weight. 9. In addition to the fact that both the Neighborhood Analysis and Affidavit do not reach the central question of predicting the adverse effect on property values of the expansion of the mining onto Mueller South, the Neighborhood Analysis suffers from the following additional deficiencies: a. The data are old and do not include any information from 2003 or 2004. It is difficult at best to develop an accurate, reliable, and valid trend of prices or to predict the future based on limited data. b. The Neighborhood Analysis shows that in 2002 the "Days On Market" for Kingswood was more than twice the average of the other five subdivisions analyzed, yet the Affiant disregards this obvious trend in reaching his conclusion. There is no explanation offered for the large difference in Kingswood with respect to the time on the market for 2002 resales. c. Although the Neighborhood Analysis describes all Expired and Withdrawn Listings in Kingswood, it fails to note that all such properties are located in the west half of Kingswood, one-half mile or more west of the Carmel Sand plant and less affected thereby. d. In the Resale Analysis portion of the Neighborhood Analysis, all but two properties are located in the west half of Kingswood. Of the two sales of homes near the Carmel Sand plant, the most recent sale indicates that in 2002 the value of such home increased only 1 .17 percent per year, which is less than one-third of the rate of increase in comparable properties located in the west half of Kingswood. No explanation for this poor performance is given in the Neighborhood Analysis, which occurred during the time that Petitioner and residents of Kingswood were before this BZA and then in court. In conclusion, the Remonstrators believe that the BZA should give no weight to the Neighborhood Analysis or Affidavit on the question of predicting the future impact on values caused by the proposed Mueller South mining expansion. Rather, the Neighborhood Analysis contains information that suggests that Kingswood is already 2 ;;' . ..- -=-- .. showing the adverse effects of the notoriety caused by the Petitioner's continued attempts at expansion closer and closer to Kingswood. Respectfully submitted, THRASHER BUSCHMANN GRIFFITH & VOELKEL, P.C., ::omeY~2~L , Philip . Thrasher, attomey no. 1075-49- Thrasher Buschmann Griffith & Voelkel, P.C. 151 N. Delaware Street, Suite 1900 Indianapolis, IN 46204-2505 Telephone: (317) 686-4773 Distribution: Zeff A. Weiss, Esq. Ice Miller One American Square P. O. Box 82001 Indianapolis, IN 46282-2100 3 .' ."", ;';';:.~. .. STATE OF INDIANA CARMEL/CLAY ADVISORY BOARD OF ZONING APPEALS DOCKET NO. 04040024 ~, I, L- 5('.)} COUNTY OF HAMILTON In re Application for Special Use Approval for Sand and Gravel Operation on 96.921 acres (Mueller South) REMONSTRATORS' OBJECTIONS TO AFFIDAVIT OF JOHN J. TIBERI COME NOW William D. McEvoy, Larry J. Kane, Greg Policka, Rex Weiper, Phil Kincaid, and Kingswood Homeowners Association, Inc. (collectively, the "Remonstrators"), by counsel, and object to the admission into the record of the Affidavit of John J. Tiberi, dated August 11, 2004 (the "Affidavit"), and in support thereof state the following reasons: 1. All of paragraph 2 of the Affidavit, except the first two sentences, is irrelevant to the Application to mine Mueller South. 2. The third sentence of paragraph 3 of the Affidavit is conjecture. 3. All of paragraph 4 should be deleted as conjecture. 4. All of paragraph 5 should be deleted as conjecture and because the statements contained therein are irrelevant to the Application to mine Mueller South. The costs of production of sand and gravel are not at issue. 5. The fourth and fifth sentences of paragraph 6 should be deleted as conjecture and because they are irrelevant. The efficiency of the operation at Martin Marietta is not at issue. Respectfully submitted, THRASHER BUSCHMANN GRIFFITH & VOELKEL, P.C., ::ome~~m(~~ Philip . Thrasher, attorney no. 1075-49- Thrasher Buschmann Griffith & Voelkel, P.C. 151 N. Delaware Street, Suite 1900 Indianapolis, IN 46204-2505 Telephone: (317) 686-4773 1 ~~ ~--,-, . -.. Distribution: Zeff A. Weiss, Esq. Ice Miller One American Square P. O. Box 82001 Indianapolis, IN 46282-2100 2 .. ....i 'j'. ~- STATE OF INDIANA CARMEL/CLAY ADVISORY BOARD OF ZONING APPEALS DOCKET NO. 04040024 ~d" COUNTY OF HAMILTON In re Application for Special Use Approval for Sand and Gravel Operation on 96.921 acres (Mueller South) REMONSTRATORS' OBJECTIONS TO AFFIDAVIT OF DAVID BUSS COME NOW William D. McEvoy, Larry J. Kane, Greg Policka, Rex Weiper, Phil Kincaid, and Kingswood Homeowners Association, Inc. (collectively, the "Remonstrators"), by counsel, and object to the admission into the record of the Affidavit (the "Affidavit") of David Buss (the "Affiant") dated August 11, 2004, and in support thereof state the following reasons: 1. This Affidavit is apparently being offered into evidence as expert testimony, but there is no resume or other evidence, apart from the statements of the Affiant himself, to establish any credentials for the Affiant. Further, it is not an independent study, but rather the opinions of a person who is apparently in the employ of the Petitioner. Therefore, this Affidavit should not be treated as expert testimony by the BZA. 2. Paragraph 5 of the Affidavit should be deleted because it states that it is based on hearsay from an unnamed person or persons at "the Carmel Utilities Department" and does not provide any date or other reference from which the information may be verified. If "the Carmel Utilities Department" is providing evidence, then the Petitioner should have a spokesperson for the Carmel Utilities Department testify as to that evidence. 3. In paragraph 6 of the Affidavit, the Affiant attempts to interpret and restate some of the conclusions in the Wittman report, which mayor may not be as intended by Wittman. The Wittman report should stand on its own merits without such interpretation by the Affiant and, in fact, the report has been revised by Wittman since the date of this Affidavit. 4. Paragraph 7 of the Affidavit should be deleted as being riddled with unsubstantiated opinions, changes of assumptions, and more hearsay, this time from "City officials." 5. In paragraph 8 of the Affidavit, the Affiant characterizes the Wittman report as being "based on a conservative set of assumptions," but there is no comparison offered to show what is meant by that statement and whether it aids or detracts from the Petitioner's arguments. 1 .- ... . - 6. In paragraphs 8 and 9 of the Affidavit, the Affiant discusses the water being "provided" by the ponds on other land owned by the Petitioner, but does not discuss that such ponds are being recharged only through the use of pumping by the Petitioner from the existing Indianapolis North Plant stone pit and that most of the water actually came from the Plant 4 aquifer in the first instance. There is no discussion of the effect on the aquifer by the cessation of such pumping. Therefore, the statements contained in these paragraphs are inaccurate by stating that the water is "provided" by Martin Marietta's ponds when it is in fact provided by Martin Marietta by recycling water from Martin Marietta's pit. 7. In paragraphs 10 and 11 the Affiant discusses a voluntary monitoring program that mayor may not actually be implemented. These are not facts and should not be relied upon by the BZA as the basis for any decision regarding the Petitioner's Application. Rather, the commitments that are offered by the Petitioner and/or required by the BZA are the only relevant issues regarding whether or not monitoring programs will exist and at whose expense. 8. In the final paragraph of the Affidavit states that "the combined monitoring program outlined by Wittman and the City substantially exceeds state or federal regulatory requirements for the City of Carmel; however, the Affiant does not indicate whether or not any such requirements actually exist and does not cite to any cross reference. Therefore, this statement should be deleted. In conclusion, the Remonstrators believe that the BZA should give no weight to the Affidavit on the question of whether or not further dewatering of the Plant 4 aquifer is a good thing for the community because the Wittman report, as revised, and the testimony by Wittman and John Duffy, together with comments from John Mundell at the August 11,2004 hearing, provide adequate and first-hand information and comment with regard to that subject. Respectfully submitted, THRASHER BUSCHMANN GRIFFITH & VOELKEL, P.C., Attorneys for the Remonstrators ~C~ hilip . Thrasher, attorney no. 1075-49- By: Thrasher Buschmann Griffith & Voelkel, P.C. 151 N. Delaware Street, Suite 1900 Indianapolis, IN 46204-2505 Telephone: (317) 686-4773 2 .... -~ ,; Distribution: Zeff A. Weiss, Esq. Ice Miller One American Square P. O. Box 82001 Indianapolis, IN 46282-2100 3