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HomeMy WebLinkAboutReport & Recommendations by Spectra ~' -,.1 \ \ '::- }I.. ///ILTBA ~ (j SPECTRA ENVIRONMENTAL GROUP, INC, SPECTRA ENGINEERING. P,C. Report and Recommendations to the City of Carmel on the Regulation of Mining Prepared for: City of Carmel Department of Community Services . One Civic Square Carmel, Indiana 46032 Prepared by: Spectra Environmental Group, Inc. 19 British American Blvd. Latham, New York 12110 January 2002 NINETEEN BRITISH AMERICAN BOULEVARD · LATHAM. NEW YORK 12110 518782-0882. FAX: 518782-0973 \ ~ CJ C'J Report and Recommendations to the City of Carmel on the Regwationof~ng Table of Contents 1.0 IN'TR 0 D U CTI ON .............................................. ............................................................... 1 2.0 SPECTRA '8 QUALIFICA TIONS ..................................................................................1 3.0 2001 S COPE OF WORK .................................................................................................. 1 .4.0 FACT FIN'DING TRIP TO CARJ.\.fE.L ............................................................................1 4.1 Meeting with Martin l\1;arietta ..................... ....................................................................2 4.1.1 The Mueller Property ....................................................... .......................................2 4.1.2 The 96th Street Facility ............................................................................................. 5 4.1.3 Hazel Dell Parkway.. .................. ...................... .................... .......................,...........6 4.1.4 The Northern Sand and Gravel Pit along the Hazel Dell Parkway......................... 7 4.1.5 Meeting Conclusion. ........................................ .................... ........ ............ ............... 8 4.2 Meeting with the City of Carmel Representatives .......................................................... 9 4.3 Meeting with Kingswood Homeowner Association Representatives ............................. 9 4.4 Meeting with Mayor James Brainard of the City of Carmel.......................................;.lO 4.5 Meeting with the Kingswood Peripheral Neighbors .....................................................10 5.0 CURRENT SITUATION AND FACTS ........................................................................11 6.0 SPECTRA RECOMMENDA TIONS .............................................................................13 Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figures Martin Marietta 96th St. Quarry Kingswood Subdivision view of Mueller Property Underground mining at 96th St. facing Gray Road Hazel Dell Parkway north of 116th St. Northern Pit exiting south, Hazel Dell Dragline on east Side of Hazel Dell Mining occurs where natural resources are located in nature Map Map 1 Mueller Property and Surrounds City of Carmel Regulation of Mining Page i #01233 \ "1 ",\ '\. u ~ Appendices Appendix I list of Attendees at Martin Marietta Materials, Inc. Meeting, December 6, 2001 Appendix II Special Use Approval Request, Developmental Standards Variance Request, and Commitment for Use of Real Estate Incident to Special Use and Variance, submitted February 2001 Appendix ill Draft Ordinance Establishing the Hazel Dell Mineral Resource Zoning District, October 30, 2001 Appendix IV Agreement between American Aggregates Corporation and the City of Carmel concerning the Construction of Hazel Dell Parkway, November 5, 1997 Appendix V Issues for Consideration re Use of Mueller Property for Mining Purposes submitted by Kingswood Homeowners Association, December 6, 2001 City of Carmel Regulation of Mining Page ii #01233 \.. "\ "'-, 'p n () 1.0 INTRODUCTION In November of 2001, the Department of Community Services (the Department) of the City of Carmel (the City) contacted Spectra Environmental Group, Inc. (SPECTRA) seeking a Statement of Qualifications to provide professional consulting services to the City. The City was in need of services relating to the development of land use policies and ordinances regulating mining and reclamation. The City was seeking a professional. firm with experience in mining regulation and development, as well as negotiations. with mine operators and other concerned parties. 2.0 SPECTRA'S QUALIFICATIONS SPECTRA represents a diverse array of clients from the large, internationally-owned quarries to small, independent sand and gravel operators in New York State. SPECTRA has extensive experience in environmental impact assessment of 'mining operations and in working cooperatively with industry, local and state governments, and the public in developing comprehensive solutions to problems for the benefit of all parties. The staff at SPECTRA has worked extensively with the Division of Mineral Resources of the New York State Department of Environmental Conservation (NYSDEC) on the state's Mined Land Reclamation Law (MLRL), on major amendments to the law, and the law's implementation in a variety of capacities. GregoryH. Sovas, Vice President of GoveI1lD;1ental Affairs at SPECTRA, was the former Director of the Division of Mineral Resources. The City determined that SPECTRA would be best qualified to provide assistance in the development of mining regulations. 3.0 2001 SCOPE OF WORK SPECTRA's scope of work through the end of 2001 included the review of a draft ordinance establishing the Hazel Dell Mineral Resource Zoning District, research, review of mining plans of Martin Marietta Materials, Inc. (MM), and a trip to Carmel in which two of SPECTRA's staff (Sovas and Psalm Wyckoff, Staff Hydrogeologist) met with the City, MM, and neighborhood groups. This report and the recommendations found within constitute the conclusion of the proposed scope of work for the 2001 calendar year. 4.0 FACT FINDING TRIP TO CARMEL SPECTRA visited Carmel, Indiana on December 6, 2001 and met with representatives of the City, MM, the Kingswood Homeowners Association (KHA), and the Kingswood perimeter homeowners. City of Carmel Regulation of Mining Page 1 #01233 \, \ , (j ('j 4.1 Meeting with Martin Marietta Representatives from SPECTRA and the City met with MM on the morning of December 6, 2001. The list of attendees is attached as Appendix I. At the meeting, MM presented the history of the mining operations. MM purchased the operation approximately three years ago from American Aggregates Corporation (AAC). Figure 1 Martin Marietta 96th St. Quarry After a long discussion of the mining operations and the proposed expansion, SPECTRA and City representatives were given a tour of the facilities at the 96th Street Plant and quarry, the Mueller Property, andthe operations along Hazel Dell Parkway (the Parkway). 4.1.1 The Mueller Property MM currently operates an established mine site within the Clay Township limits. When the existing sand and gravel operation north of 106th Street and west of the Parkway expanded into the parcel known as the Mueller property in 2000, the KHA filed suit in an attempt to halt the mining operation. A partial summary judgment was issued stating that the property was deemed to be in an "urban area" and under the jurisdiction of the City. MM voluntarily ceased mining on City of Carmel Regulation of Mining Page 2 #01233 ! ; u u MM offered several commitments with the Special Use Approval Request. Among numerous commitments, MM proposed that surface mining north of 106th Street would be limited to dredging of sand and gravel creating an artifiGiallake. MMwould not surface mine the wooded portion of the Mueller property. The Developmental Standards Variance Request included a reduction of the surface mining setbacks from 300 feet to150 ft adjacent to residential properties and 100 ft adjacent to all others. MM committed to "use its best efforts" to obtain agreement from the Mueller property owner to convey the portions of the Mueller property between the lake ...._ ___!!!!~_~he...~~l~t?n!..~rQP~t1!..~~.JQJh~l!~~..Q~J:l~~~_,_a~~..!.()__I;.().J:l.Y-~YJQ....!!t.t?.~gy_~__tigh~_Qf.~.~Y._l:lJQI}g..._..._ ..-.. 106th Street to allow for a pedestrian walkway from the Parkway to the park at the corner of 106th and Gray Streets. These conveyances would occur after all operations on the northern portion of the Mueller property were completed. City of Carmel Regulation of Mining Figure 2 Kingswood Subdivision view' of Mueller property MM proposed that setbacks for underground mining north of 106th Street would be increased from .500 ft from residential properties and reduced to 100 ft from all others. Average air blast and ground Page 3 #01233 u (j vibration readings for any year would not exceed 110 dB and 0.10 in/sec, respectively (the averages for 1999). Maximum air blast and maximum ground vibrations would not exceed 125 dB and 0.5 in/sec, respectively. Blasting would be restricted to the hours between 10:00 am and 5:00 pm. MM withdrew its petition for Special Use Approval in June 2001 in response to indications from the Board of Zoning Appeals (BZA) and others that they preferred a legislative determination, in the form of zoning, as opposed to a quasi-judicial one made by the BZA. MM opted to pursue an ordinance establishing a Planned Unit Development (PUD) on the Mueller property. At that time, the KHA indicated that the pun was the preferred resolution. MM provided the Draft Ordinance Establishing the Hazel Dell Mineral Resource Zoning District on October 30, 2001 (Appendix Ill). The PUD covered only the Mueller Property; all other MM, real estate was excluded. The proposed .PUD stipulated that surface mining north of 106th Street would be limited to the extraction of unconsolidated materials. The extraction of consolidated materials north of 106th Street would occur below ground. Setbacks in the northern portion of the Mueller Property included a 100 ft setback from property line for surficial mining. The 100 ft. setback area could be affected by access roads, berms, topsoil storage pile, signs and buildings. A visual mitigation berm would be constructed and set back from the property line by 10 ft. Fencing would be required along road right-of-ways and at the toe of the visual mitigation berm along the Kingswood neighborhood. Mining would be prohibited on Sundays. ,,___~'Eia~~J~!~_tiE.8._S~~!~?!19_~~_~~~t w~~~c!!?~_!i~!~~~~__~~_l!~~~ _of 10:00 ~_~_d_~~.9Qp_m on weekdays. Surface blasts could not be detonated on holidays recognized by the State of Indiana. The PUD stated that accepted blasting practices would be used, but are not specified. Blasts would be monitored at the Monitoring Station. Other monitoring locations were not addressed. Blasting and monitoring reports would be available for inspections for up to three years. . The maximum ground vibration would be limited to 2.0 inches/second. The maximum air blast would be 129 decibels. Averages for surface and underground mining would be maintained. A blasting report with averages would be produced by MM annually. The PUD stated that the underground mining would be conducted with sufficient lateral support to be safe, but did not specify any geophysical studies made or dimensions of the mining operations. Underground mining would be set back from residential structures 300 ft. The PUD did not require a comprehensive mining plan or reclamation plan. The PUD stated that prior to reclamation- activities, MM would present a reclamation plan to the City. The PUD did not require the identification of the ultimate reclamation objective but did propose several City of Carmel Regulation of Mining Page 4 #01233 w w possible post reclamation land uses. MM is in the process of developing a mining and reclamation plan for the Mueller property north of 106th Street. 4.1.2 The 96th Street Facility Underground mining at the MM facility began in approximately 1987. Currently 75 % of mining at the site is done underground. MM did not provide information regarding the structural or geological engineering for the underground mining other than the rough dimensions of the rooms (25'hxI45'w) and the depth below grade (approximately 168 ft bg). Underground blasting occurs approximately six times per day at a volume of 1000 tons each. Underground mining has extended from the west side of the open quarry under Gray Road approximately halfway to the w~stern property line. Figure 3 Underground mining at 96th St. facing Gray Road The average above- ground blast is approximately 40,000 to 50,000 tons. MM did not provide any information regarding blasting design other than stating that electronic detonation is used. MM did '-not--provide--any--record-of--- blasting monitoring or complaint logs. MM has observed that most complaints from the Kingswood development seem to occur when ,shots are detonated on the southern face of the quarry. They stated that the number of complaints had diminished since MM purchased the operation. MM did not provide hydrogeologic information regarding quarry capture zones, groundwater volumes handled by the quarry, how the expanded quarry will affect the local water table, or the expected increase in volumes of water handled. Anecdotally, MM stated that the two dewatering pumps pump 3000 gallons per minute (gpm), 24 hours per day, seven days per week. MM said they do have a National Pollutant Discharge Elimination System (NPDES) permit for the quarry pump out discharge. City of Carmel Regulation of Mining Page 5 #01233 u Q 4.1.3 Hazel Dell Parkway On November 5, 1997, the City and AAC, predecessor to MM, made a legal agreement with respect to the Parkway right-of-way (Appendix IV). The Parkway route would negatively impact the mining operations and reserves. Rather then incur the expense of exercising the power of eminent domain, the City and AAC made the legal agreement to transfer the surface ownership of the Parkway right-of-way. Figure 4 Hazel Dell Parkway north of 116th St. The agreement recognizes that AAC has and is conducting mining operations on its real estate, and acknowledges that AAC will. conduct mining operations of all of its real estate in Clay Township. The agreement states that AAC leases land for use by industries that are subordinate to and related to the mining operations. The City agreed not to participate in any action that. would limit or prohibit AAC mining operations or the related industries located on their real estate or sue AAC for damages resulting from non-negligent operations. The main use of the 96th Street facility is the "complete use" of its mineral resources. The agreement recognized that the 96th Street facility was outside an urban area at that time, and therefore, the City could not prohibit AAC's "complete use" and alienation of the any mineral resources located on or beneath their real. estate. The agreement recognized that, at the 96th Street facility, there were certain uses that are subordinate to and that benefit the mining operations, all of which had been in existence for a considerable number of years. The City agreed to allow AAC to move existing asphalt batch plants from real estate south of 96th Street to the facility located north of 96th Street. The asphalt batch plants are subordinate in use to the main use of the facility and were considered a permitted accessory use. In addition, the relocation of the asphalt batch plants resolved traffic safety issues related to the Parkway. City of Carmel Regulation of Mining Page 6 #01233 u w AAC agreed they would not conduct surface mining within 100 ft of the right of way or property line. Underground mining would be pennitted beneath the Parkway at a depth greater than 50 ft below the surface. The agreement allows AAC to stop.traffic once per day on the Parkway if required for additional safety when detonating a blast. Blasting that required stopping traffic was limited to the hours of 9:00 to 11 :00 am and 1 :30 to 2:30 pm. The City and AAC recognized in the agreement that the City might annex the AAC real estate into the city limits in the future. AAC agreed not to oppose annexation so long as the City recognized the mining operations as an existing, legal non-confonning use. The City agreed that the annexation would not divest AAC of its mining rights pursuant to such legal non-confonning use and that the real estate would be initially treated by the zoning ordinance as if it was outside an urban area. The City agreed that it would not object to any proposal by AAC to rezone the real estate for mining operations and the operation of accessory uses (inciuding the asphalt batch plants) so long as the rezoning was consistent with the City's comprehensive plan. 4.1.4 The Northern Sand and Gravel Pit along the Hazel Dell Parkway The Plant is located ort the west side of the Parkway. The dredging operations have created a sizable pond between the Parkway and the Kingswood neighborhood. Dredging operations have recently commenced on the east side of the Parkway to compensate for MM's inability to access the reserves on the Mueller Property. As a result, MM contends that they may no longer have room to move the plant to the east side of the Parkway as initially proposed in earlier discussions with the Kingswood homeowners. Figure 5 Northern Pit exiting south, Hazel Dell City of Carmel Regulation of Mining Page 7 #01233 (J Cj Figure 6 DragIine on east side of Hazel Dell 4.1.5 Meeting Conclusion SPECTRA concluded the meeting by requesting from 'MM the following: historic and legal documents. including the Hazel. Dell Parkway Agreement, blasting records, complaint records, a comprehensive mining plan and reclamation plan, geological and geophysical studies of the quarry and underground operations, and hydrogeologic studies. To date, 'MM has provided the Hazel Dell Parkway Agreement, the December 20, 2000 CarmeVClay Technical Advisory Committee Minutes, the May 3, 2001 City of Carmel Department of Community Services Department Report, and the Commitment for Use of Real Estate Incident to Special Use and Variance. 'MM has also provided information and videotapes on community relations efforts. 'MM has indicated that they would consider and not be opposed completely to a comprehensive mining ordinance so long as the ordinance does not interfere with their rights as an existing non- conforming use and does not restrict their current operating methods. Any ordinance would apply equally to all mining entities within the jurisdiction of the CarmeVClay Plan Commission and notjusttoMM. The issues that MM sees as a hindrance to resolution of the problem are the neighbor's concerns relating to mining sequence and the ultimate reclamation. The KHA and the property owners along the periphery of the development are not. in agreement regarding the mining sequence and the ultimate reclamation objectives. MM would like to work cooperatively with the homeowners, but because of the changing conditions and the lack of unanimity, they are unsure as to how to proceed. MM did not provide a mining and reclamation narrative or map for the Mueller Property, stating that they had not yet been developed. City of Carmel Regulation of Mining Page 8 #01233 (j (j It should be noted that SPECTRA requested information at various times during the meeting. At times in this report, SPECTRA has stated that :MM did not provide certain information; however. MM stated that they were willing to provide SPECTRA with whatever information we wanted, but at that time. the information was not available in the form that was requested. :MM indicated that they would cooperate fully with SPECTRA, the City. and the homeowners to reach a resolution. 4.2 Meeting with the City of Carmel Representatives SPECTRA met with various City representatives on the afternoon of December 6, 2001. Concerns were raised by the City with regard to the impacts of blasting on the adjacent water treatment plant facilities and the utility lines that run parallel to the Parkway. No damage has been attributed to blasting at MM's facility to date. The City representatives want some assurances that there will be no damage in the future. The City representatives indicated that they have no current concerns for the water supply wells located north of the :MM facility. There are several creeks that act as groundwater divides between the quarry and the wells. and the City representatives believe these creeks preclude adverse impacts to the groundwater at those locations. The City representatives indicated that they are considering siting a supply well closer to the :MM facility and that local impacts to groundwater around that quarry have not been adequately addressed. The City representatives indicated that the primary concern at this time is the protection of neighboring residences from the impacts of blasting. dust. noise, trucks. road maintenance and other environmental concerns. The City representatives indicated that the preferred resolution would be a mining ordinance that covered all of MM's operations. 4.3 Meeting with.Kingswood Homeowner Association Representatives SPECTRA met with representatives of the KHA (Mr. Yedlick and Mr. Booher) on the afternoon of December 6. 2001. The KHA presented a list of issues for consideration regarding the use of the Mueller Property for mining purposes (Appendix V). The primary concerns are related to adequate comprehensive mining plans and reclamation plans, including mining and reclamation phasing and reclamation objectives. The KHA wants the consolidated and unconsolidated operations to be considered separately. The KHA feels that :MM should be held to higher operational standards than they are currently. In addition to these written issues. the KHA had several other concerns, including excessive noise impacts and hours of operation related to noise. The KHA is concerned that blasting will go from 85% below ground to 85% above ground if the Mueller property is developed as an open quarry. They are concerned that the frequency of City of Carmel Regulation of Mining Page 9 #01233 ~,::::d u u blasting and the closer proximity will increase, and that this will result in negative impacts to residential structures and humans who are intolerant of vibrations. They believe that they are affected currently by the underground blasting as well as the above ground blasting at the 96th Street facility. The KHA alleges that MM ignores their complaints about blasting, and that the neighbors to the west of the MM facility have stopped complaining due to the lack of response. The KHA alleges that MM has treated complaints with disrespect and threats, and thatMM is using the creation of a recreational lake as leverage to obtain approval for the entire operation. They also allege that the seismograph that was once located in the Yedlick yard has been removed for reasons not disclosed by MM. The KHA alleges that MM desires to expand the open quarry because it is more economical than mining underground. The KHA contends that the asphalt plant, concrete facility, trucking, and recycling operations present on the site are not mining, and therefore, are not legal non-conforming uses. The KHA made it clear that their preference would be to prohibit mining on the Mueller property. Short of that goal, the KHA desires a mining ordinance that would regulate all of MM's mining operations and that operating standards are the most stringent applicable. They would like the property around the lake to be converted to a park for the private use of the Kingswood residents. 4.4 Meeting with Mayor James Brainard of the City of Carmel SPECTRA met with Mayor Brainard and others on the afternoon of December 6, 2001. The Mayor believes that MM is a good corporate citizen but recognizes that the homeowners have concerns that need to be addressed. In finding a solution to the problem, the Mayor needs to protect the neighbors in the Kingswood neighborhood. The Mayor desires a resolution that reasonably satisfies all parties. 4.5 Meeting with the Kingswood Peripheral Neighbors SPECTRA met with representatives of the informal delegation of Kingswood peripheral homeowners (Mr. Sveen, Mr. Lolley, Mr. Broach, and Mr. Thyne). The peripheral homeowners own the properties on the outside perimeter of the Kingswood neighborhood that are directly adjacent to the MM operations and/or the Mueller Property. The residents on the periphery of the Kingswood neighborhood are most directly affected by MM's operations. They estimate that approximately 90% of the peripheral homeowners are not in agreement with the KHA and are not happy with how the KHA has handled the negotiations with MM and the City. City of Carmel Regulation of Mining Page 10 #01233 ii::.~ .. u u The peripheral neighbors' primary concern is blasting. They believe that blasting is a manageable nuisance today with a tolerable frequency. They' want assurances that as the biasting, both above and below ground, approach their homes, there will not be structural damage, and their property values will not be adversely affected. Other concerns the peripheral neighbors have relate to noise and hours of operation, groundwater, and erosion control. The peripheral neighbors are concerned about the surface mining sequence in the northern portion of the Mueller property. They would like commitments from MM that the mining would be conducted in such a way that the impacts and the duration of mining are reduced to a practicableextent. The peripheral neighbors want to see a clear mine plan and reclamation plan. They are concerned about the ultimate reclamation objectives for the Mueller Property. The peripheral neighbors do not want public lands behind their homes. They would prefer to purchase the lands located directly adjacent to their properties to preclude any accusations that they unfairly. benefited from the arrangement. .5.0 CURRENT SITUATION AND FACTS The KHA has a pending lawsuit regarding mining the Mueller property which may prevent MM from extractirig unconsolidated materials. MM has voluntarily stopped mining on the Mueller property pending resolution of the matter. MM has withdrawn the Special Use Approval Request and the Developmental Standards Variance Request and has presented a draft PUD for the Mueller Property as an alternative. The KHA and the City would prefer to see an ordinance' that regulates all the MM mining operations on all properties. MM would not be opposed to such an ordinance so long as it does not impinge on their prior non-conforming use status and does not restrict their current mining operating practices. It appears that there is a great deal of misinformation arid.mistrust among all of the parties. On the one hand, MM has shown itself to be an outstanding member of the community, wanting to do what is necessary to satisfy the community and to meet the reasonable needs of the adjoining landowners. MM is requesting a rezoning of the Mueller property in proximity to residences that clearly will impact the homeowners. MM has also purchased the quarry a few years ago and does not appear to have a comprehensive public plan for the existing and future mining properties and ultimate reclamation. This conclusion does not mean to suggest that MM is unwilling to present such a plan for the public's understanding of its mining and reclamation plans. Rather, MM has not owned and operated the properties for a sufficient period to evaluate the extent of the mining reserves and to understand and communicate fully its plans for the future. On the contrary, MM's efforts in reaching out to the community in a host of venues, City of Carmel Regulation of Mining Page 11 #01233 -. u u including the extraordinary concerts in the quarry, indicate a real commitment to Cannel. MM is one of the national leaders in its public and community relation's efforts. Figure 7 Mining occurs where natural resources are located in nature From the perspective of the homeowners in the vicinity of the mine, they are concerned about the impacts of mining upon their residences, including any diminution of property values. They are mostly concerned because they do not know, with any certainty, the real plans of MM to mine and reclaim their holdings. Much of the suspicion is a result of the lack of any comprehensive mining ordinance or regulation that would require such information and make that information public so that the public could state its views to the policy makers in the community. SPECTRA experienced excellent cooperation from all of the parties, particularly the willingness to discuss problems and concerns candidly. While SPECTRA may not have agreed with everything that was said, we genuinely appreciated the cordial and civil response to our less than informed questions. MM showed an exceptional effort to answer all of our questions and to cooperate with our requests for further information. City of Carmel Regulation of Mining . Page 12 #01233 u o 6.0 SPECTRA RECOMMENDATIONS After SPECTRA's review of the situation and discussions with all of the parties in Carmel, the most appropriate solution for the City of Carmel is to comprehensively review all of the mining properties and insure that reclamation .of these properties will be consistent with the overall comprehensive land use plaDning objectives of the City. This review would be accomplished by the adoption of a mining.and reclamation ordinance. It will be critical for the City to gain the trust, confidence, and cooperation of MM and to recognize that MM has certain non-conforming use rights that cannot be extinguished or diminished by the adoption of standards. within the ordinance. However, there may be some requirements or standards within the ordinance that would require MM to upgrade some of its facilities or current operational practices. The New York" State Miried Land Reclamation Law provides a good starting point and framework for the proposed local law or ordinance. In essence, the NYS law requires that a mining .operator submit mining and reclamation plans for the life of the entire operation at that site. The mining operator must design his mining operations to minimize environmental impacts to the maximum extent practicable. Noise, dust, blasting, integrity of underground mining, hydrogeology, and traffic are some of the issues that would need to be addressed. The plans are then reviewed and approved before a permit is issued to the mining operator. A permit is issued referencing the plans submitted and contains operating conditions for the mine. So long as the mining operator complies with the conditions and the mining plan in terms of sequence and mining operational processes, a renewal" permit is issued every five years until the mine ceases operation. When mining stops, the operator has two years to reclaim the mine site in conformance with the approved reclamation plan. The operator also needs to identify any concurrent reclamation that would be undertaken or explain why concurrent reclamation is not possible. Following the framework of the NYS Mined Land Reclamation Law will not adversely affect MM's current and future operations. The NYS law was designed to mirror how a responsible mining party will plan for its operations, although it is apparent that MM will incur additional expenses to comply with any new law or ordinance. The public, including the homeowners in the Kingswood subdivision, need to know the mining and reclamation plans of MM, and should be afforded an opportUnity to review and comment on these plans that will impact the entire community of Carmel. City of Carmel Regulation of Mining Page 13 #01233 r , ~ :r~Ro~~I~~E:HD~~~ LfmD O~S ca~~ 0: ::::l~ <~:t:ft~.c~c::;.~.in.u5/"'P/)). PROPERTIES LISTED UNDER OTHER NAMES BUT ACTIVELY ARE MINED NOT INCLUDED. PROPERTES HELD BY MM SOUTH or 96TH STREET NIlT 'SH[J\ffl. MAP MAY NOT INCLUDE RECENT PROPERTY TRANSACTIONS. , , MAP 1 ~ Iff'SPEr:rRA ENvIRoNMENTAL GROUP. INC. MUELLER PROPERTY AND SURROUNDS 19 British American Blvd. CITY OF CARMEL Latham. NY 12110 , MUELLER PROPERTY CITY OF CARMEL HAMIL TON CO.. IN ~ROJ. No.: 0123311 OA TE: 12/26/01 II SCALE: 1"=15oo'lr OWG. NO. 012330111 PAGE 14....,.j