Pictures of a win/lose situation

Buffalo County (like many others in this region) is locked in a win/lose battle where either mining interests are going to win or the people who oppose them will win.  As long as we continue to frame the discussion the way we have, somebody has to lose.

Here are three maps to describe what is happening.  I used to lobby that we should try to figure out a way to turn this into a win/win conversation where opportunities and way of life are preserved for all of us rather than those of us who win.  I’ve given up on that, and now focus on supporting county and region-wide efforts to stop these projects.  I still believe there’s a path to win/win but the miners aren’t listening.

Our county: Divided by incompatible land-uses

In the southeastern two thirds of the county lies the unique river and coulee country (a part of the unique and fragile “Driftless Area” habitat) where the focus is on recreation and tourism.  In the northeast are the rolling sand hills that actually extend across much of central Wisconsin all the way up into the northwestern lakes region where the economic emphasis is more on agriculture and small industry.


A bad idea: Turning the Coulee Country into a transportation corridor

This is a representation of the situation that will develop as sand trucks from mining sites are routed through the Driftless Area Coulee Country on their way to destinations in Minnesota.  This is a classic “win/lose” situation where one side will prevail at the expense of the other.

Each side of this win/lose conversation is afraid of losing the battle.  That fear is turning into anger, the anger has split our communities.  This, in my view, is a Bad Thing.

Many of the mines depicted in this drawing have been denied or are being opposed in court.  And the two Minnesota loading destinations are at capacity and no longer accepting additional traffic.  This, in my view, is a Good Thing.


A really bad idea: Turning the Coulee Country into a transportation hub

But the stakes in the win/lose conversation get even higher if the Driftless Area Coulee Country becomes a transportation hub.  Permits have been repeatedly sought to build a rail spur and frac sand loading facility at the intersection of Wisconsin highways 88 and 35.  If that (or a similar) facility gets built along the Great River Road we not only become the transit provider for local sand, but regional sand will start flowing into the county as well.  Winona’s processing facility has been closed to Wisconsin sand trucks, with Wabasha probably not far behind.  What happens to the Coulee Country in a scenario like this?  It’s not surprising that people are frightened.

Two separate attempts to build this facility have been turned back through concerted community effort.  Over 2500 people participated directly or indirectly in the latest round.  This, in my view, is a Good Thing.


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Mike’s Testimony OPPOSING Klevgard Application for CUP Modification


Date:    May 4, 2014

To:    Buffalo County Board of Adjustments

From:    Mikey O’Connor (

Re:    Testimony OPPOSING Klevgard Application for CUP Modification


Please deny this application for the following reasons:

  • Allowing such a wide variety of haul routes makes it impossible to assess the impact of this mine on public health, safety and welfare.
  • Expanding the length of the permit from its original 5 years to 20 years is unnecessary.  Nothing prevents Klevgard from completing his plan under a regime of 5-year renewals.
  • Expanding the length of the permit from its original 5 years to 20 years is irresponsible.  Buffalo County needs periodic reviews to protect public health and safety and ensure that this marginal operator complies with his CUP.
  • The application materials have substantial irregularities that should have been addressed before they were even brought to the BOA for consideration.

Impact on public heath, safety and welfare

The applicant is requesting two additional options for hauling.  Approving this application will mean that Buffalo County residents along all three haul routes will spend the next 20 years in a state of uncertainty as to whether 125 loads of frac sand will be rolling by their homes and businesses, with the attendant impact on business operations and property value, on any given day.

This extreme diversity of routes makes it impossible for Buffalo County to assess the public heath and safety impact of the mine, since at any given moment the trucks might be going in any one of three completely different directions.

One of the duties of Buffalo County is to assess the cumulative impact of mine operations on the county.  This too will be impossible, again because of the uncertainty of the impact from Mr. Klevgard’s proposed hauling operation on the region.

Expanding the length of the permit is unwise and unwarranted

Klevgard appears to be a marginal operator that needs a fair amount of supervision, given that he just barely got the Reclamation Plan approved in time to meet the 2-year start-up window in his CUP.

Klevgard is out of compliance with the paved tracking pad and tire-cleaning conditions of his CUP if he has shipped any product.  Condition #2 of his CUP states that the tracking pad must be paved at a minimum of 200’ from Highway 88.  That condition goes on to state that the paving must be complete prior to any product leaving the site.   Here is a picture of the Klevgard operation taken today (May 4, 2014).

Mr. Klevgard has also been cited for shipping product without a permit at various times in the past.

All of this, taken together, indicates that Mr. Klevgard is an operator who needs a fair amount of adult supervision.  Extending the length of time between reviews of his operation from 5 years to 20 is unwise.

This extension is also unwarranted.  The application for modification states “there’s no feasible way to extract the minerals in 3 years, and execute the reclamation plan that has been approved without being in total disregard to the landowner and the surrounding communities.”

  • Nowhere does it say that all the minerals have to be extracted in five years.  If Mr. Klevgard needs more time to complete his excavation, he can file for another permit and, if all is going according to plan, it seems likely that it would be approved.
  • Every time Mr. Klevgard has appeared before the BOA his whole pitch has been his innovative small-acreage approach to mining and that the reclamation will be happening in tandem with excavation.  Thus, reclamation on the land that has been mined should be complete shortly after excavation is finished.  That was the whole point of the presentation that was made to the Board of Adjustments mere months ago.  Suddenly this is no longer feasible?  What has changed?
  • What is the basis the language “total disregard to the landowner”?  Klevgard is the landowner.  This language implies that somebody else is writing it.  But no other name appears on the application?  What are the issues that are being disregarded?  This language raises more questions than provide answers.

This request is an unwarranted attempt to make life easier for Klevgard (and unnamed others) at the expense of the rest of the citizens of Buffalo County and the region.

Irregularities in the application and the notice of the hearing

  • Mr. Bublitz of the Zoning office provided me with a signature page dated April 29th, a letter of justification dated April 30th, and a letter from the Gilmanton Town Chairman dated April 28th.  The Notice of Public Hearing was published April 24 and May 1, but the hearing is being held May 6th.
    • The public (and the BOA) has had less than a week to review material documents prior to the hearing.
    • The Public Hearing is less than a week later than the second publication date of the notice.
  • It is not clear whether the letter from the town of Gilmanton is the result of a properly-noticed town meeting or just a personal letter from the town Chairman, Mr. Meier.
  • Opinions may differ as to whether Condition #34 (the removal of the knoll on the Lisowski property) has actually been met.  Mr. Meier attests that “the site clearance on Loesel Road has been performed “to the Town of Gilmanton’s recommendations.”

    I inspected that knoll on May 4th and found minimal evidence that the knoll has been removed.  Since Klevgard has included the letter in his application (and thus made it part of the record for you to consider in your deliberations), I hope the BOA will visit that knoll as part of the site visit and form your own view as to whether that condition has been met.

  • The application form states that Mr. Klevgard is the owner.  The application form does not refer to Aaron Keopple or Advanced Sand and Proppants.  However, the letter of justification indicates that ASP owns the mineral rights to the sand that will be mined, and will be “assisting” Mr. Klevgard.

    Since the operational expertise (drilling, blasting, quarry operation, etc.) and mineral rights reside with Mr. Keopple and ASP, aren’t they really the operator of the mine?  Shouldn’t they be listed on the application form, and be held accountable for the success or failure of this mine, along with Mr. Klevgard?

Approving an application with all these irregularities establishes a terrible precedent for other mine operators to follow.  It sends a signal that applications can be out of compliance with public notice requirements, and downright misleading, without risking any adverse consequences.

Approving an application that introduces this much uncertainty over haul routes does an enormous disservice to property and business owners of Buffalo County and the region that surrounds it.  Not to mention the inability to assess the health and safety impacts of a constantly changing haul route through one of Buffalo County’s largest towns.

Approving an application that extends the time between opportunities for reviews and course corrections from 5 years to 20 is inconsistent with previous depictions of this mine as an innovative “small footprint” operation.  It’s also a terrible idea given the track record of this applicant.

Please deny this application.

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Mike’s testimony opposing Segerstrom mine expansion


Date:    April 20, 2014

To:    Buffalo County Board of Adjustments

From:    Mikey O’Connor

Re:    Testimony OPPOSING the Segerstrom application to change their existing CUP.

Please deny this application and require that it be considered a major change to the CUP.  This CUP was one of the very first frac sand mining CUPs granted in the County, and serves as a great example of a bad one.

Over the last several years, the County has established a much better framework to document, evaluate and approve sand mines – largely in reaction to lessons learned from these very early CUPs, which did not do an adequate job of protecting the interests of Buffalo County.

While it is unrealistic to think that this mine can be shut down at this stage in its development, it is important to reign in this reckless operator and subject the mine to the requirements that we have imposed on later applicants.  Treating this application as a “minor change” without acknowledging the substantial issues associated with it is a disservice to the citizens of Buffalo County.

Reasons why this is a “Major Change” to the Segerstrom CUP:

1.    This application asks for a material change to the size of the mining operation.  The original reclamation plan states that the total area to be mined is projected to be 450 acres.  This plan reduces that by more than half, to 159 acres while at the same time requesting a wet plant.  The goal of this application appears to be to change the primary business of this operation from being a mine to being a processing plant.
2.    Current CUP does not limit the number of outbound loads shipped, does not specify destinations and does not specify haul routes.  How can the Board of Adjustments evaluate the health and safety impacts of this mine due to outbound truck traffic with the information it has in front of it?  This has been seen repeatedly as a crucial public policy issue in other applications, yet this application (and CUP) is mute on that topic.
3.    Current CUP does not limit the number of inbound loads shipped, does not specify sources of those shipments and again does not specify haul routes.  Since it appears that this application is paving the way for Segerstrom to become a regional wet-processing plant for regional mines –long after the (now reduced) mine has been wrapped up.  This represents a huge loophole, which could cause endless trouble for Buffalo County citizens for decades and which ought to be rigorously documented and reviewed before the revised CUP is granted.
4.    The current CUP specifies a 5-foot separation from groundwater, yet the proposal shifts the mine boundary to within 100 feet of the Buffalo River.  How can a mine be moved that close to a river and still operate within that groundwater-separation standard?  Where is the documentation upon which to make that determination?
5.    The original Reclamation Plan describes several locations on the mine site that are “too steep to reclaim” and implies that those areas will not be mined – yet the Segerstrom operation has already destroyed one of those steep hillsides and now proposes to expand mining in these “too steep to reclaim” steep-soils areas.  Here is yet another reason why this application ought to be subjected to the rigor of the current application and review process.  Where is the analysis of the impact on the scenic beauty of the region, not to mention the environmental impact and habitat loss that will result?
6.    There are substantial property-line discrepancies between the original Reclamation Plan description of the mine, and the current proposal.  See the attached diagrams for several examples of where A) there are sizeable differences between the boundaries of the property and B) mining is proposed in what are likely to be disputed lands.  There is no indication that a qualified surveyor reviewed the diagrams or maps associated with any of the Segerstrom CUP applications.  Shouldn’t the County require that before granting this application?
7.    The current CUP does not specify a setback for mine boundaries.   While the original reclamation plan describes what appears to be either a 50 or 100-foot setback, the CUP is mute.  The proposed mine diagram encroaches on that original setback in key locations.  In some cases, the encroachments put the mine boundary very close to the Buffalo River (and Highway 37).  In other cases, the reduced setbacks increase the risk of encroaching on neighboring lands.

This is primarily an appeal for due diligence and proper process.  Please deny this application and let that happen.

Starting point: Slide06

This is the mine layout contained in the Reclaimation Plan.  I’ve overlaid colored boundaries in order to create layers that compare the original Rec. Plan with the new proposal.

New proposal:


This is an overlay based on the proposal that is before the BOA.  Again, just colored boundaries overlaid on top of a map provided by Segerstrom.

Overlay 1


This map puts the two maps I drew on top of each other.  It emphasizes the boundary issues that are raised by discrepancies between the original Rec. Plan and the new proposal.

Note that the property boundaries in the two proposals align well along Highway 37 and the southwestern boundaries.  These are easy to determine from satellite imagery.  However, discrepancies appear in the wooded areas to the north and west.

Overlay 2


This map also overlays the two maps.  This version emphasizes the environmental issues that are raised by differences between the original Rec. Plan and the new proposal.

Traffic Map 1


This map highlights the fact that there are no CUP conditions on this mine with regard to processing sand from sources other than the mine itself.

Given that the mine is getting much smaller, one has to wonder whether the real reason for this “minor change” is to develop a regional processing plant to service and enable other mines.

Traffic Map 2


This map describes the problem with the lack of CUP conditions describing outbound haul routes and destinations.

There are no conditions on how many loads/day of processed sand, or the destination of those loads.  There are indications in meeting-notes that 100 loads/day is the target, but there are no CUP conditions to enforce this limit.

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Segerstrom mine — application to add wash plant and high capacity well

The Segerstrom mine is applying for an amendment to their Conditional Use Permit (CUP) to add a high-capacity well and a sand washing plant to their mine located on Highway 37.  They say this is just a minor routine amendment – “nothing to see here, just move along please.”

I disagree.  This is a major change to their operation — because it puts them in a position to be a regional processor of frac sand long after the local mine is done.

This is especially important because the Segerstrom permit is one of the very first ones approved by the County back in the days when nobody was paying attention.  So unlike today where we have the benefit of a much more rigorous zoning ordinance and a much more detailed set of requirements to file an application for a sand mine or a processing plant, there are virtually no limits on what Segerstrom can do.

  • There are no limits on the number of trucks per day
  • The only limit on haul routes is that they must stay on State highways
  • There is no fixed haul route specified, and these could change at any time

Here are a few maps to give you a sense of the trouble we will be in if this application is approved.

Segerstrom could become a regional processing site for frac sand

Segerstrom sources map

The bulls-eye shows approximately where the Segerstrom mine is, on Highway 37.  The incoming arrows show all the places where sand could be coming from in order to be washed at Segerstrom’s.  The current permit places no limit on the number of trucks, the locations they could be coming from. the routes that they are required to follow or the hours of the day that they are prohibited from running.  If you live along any of these routes, you are at risk of an unpleasant surprise that could come along any time over the next 20 years or so.  Imagine what that uncertainty is going to do to your property value.

Segerstrom can ship his sand anywhere, and change his route at any time

Segerstrom destinations map

The Segerstrom permit also makes no mention of where sand will be shipped, the number of trucks, the route that it will take or the hours of operation.  So here’s a map of all the options.  Again, if you live on any of these roads, your life could change over night if the Segerstrom operation finds a better deal on selling or loading their sand over the life of that plant.

Just a reminder of promises not kept

Segerstrom stated on the record, at least twice, that no trees would be taken down.  He also said that no more than 10 acres would be open at a time.  Here’s a picture of the site I shot a little over a year ago.  Draw your own conclusions.  You can see a few more versions of this picture in the original blog post — click HERE to see that post.

Next meeting — you can help

The Board of Adjustments is meeting on April 23rd (3pm, at the Buffalo County Courthouse) to consider this modification to the Segerstrom permit.  Click HERE to go look at the details of the meeting on our “Meetings” page.

I’ll be there — I’ll be asking them to consider this a major change to their permit, one that should go through the whole permitting process rather than just the abbreviated one that is allowed for minor changes (which is currently what is on the table).  Please join me — this is a change that has county-wide impacts.

Background information

Here’s a set of links to various documents you may find useful:

  • April 2014 — Reclamation plan additions to accommodate the new wash-plant plans.  Click HERE for the revised plan, HERE for Figure 1 Site Location Map, HERE for Figure 2 Site Plan View and HERE for Figure 3 Site Detail.
  • January 2014 — Application for CUP to add high-capacity well and wash plant to the operation.  Click HERE for the file.
  • May 2013 — Frac Sand Frisbee blog post — “Is Buffalo County Sand Any Good?” — features the failure of Segerstrom’s dry processing plant failure to clean the sand to be marketable.  Click HERE for the post.
  • February 2013 — a diagram from Land Resources office showing approved mines and haul routes listing Segerstrom as approved for 100 loads a day.  Click HERE to view the file
  • January 2013 — Frac Sand Frisbee blog post — pictures of the Segerstrom Mine — showing how they’ve torn the whole front of the bluff off — so much for “no trees will be taken down.”  Click HERE to see the post.
  • January 2012 — Minutes of BOA meeting where Condition #7 (prohibiting blasting) was removed.  Click HERE to view the file.
  • September 2011 — Reclamation Costs and Bond (in which Segerstrom again claims that no trees will be taken down on the site).  Click HERE for the file.
  • September 2011 — Reclamation Plan.  A good source of site-maps (plow through the boilerplate, the maps are at the end). Click HERE for the file.
  • July 2011 — Original decision of the Zoning Board of Adjustment granting conditional use permit.  Click HERE for this 500k PDF file.
  • July 2011 — Minutes of the BOA meeting where the original permit was issued (source of the 100 trucks/day estimate and Segerstrom claiming not to take trees down).  Click HERE for the file.
  • The Zoning Department responses to the seven factors that must be considered in a Conditional Use Permit — for the Segerstrom and the Barth permits. Click HERE for the PDF version.
  • The conditions placed on the permits for Barth and Segerstrom — Click HERE for the PDF version.
  • Aerial photo of the mine site — click HERE
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Badger Bluff Sands permit denied on 3-0 vote by BOA

The Badger Bluff Sands application for a sand mine spanning Schoepps Valley Road and Oak Valley Road was soundly defeated this week after comprehensive and well-researched testimony against it, for all sorts of reasons.

What became clear during the testimony is that Kevin Rich, the mine promoter, hasn’t made much of an effort to win his neighbors over.  Although Kevin spent the day addressing us all by our first names as we asked questions during a site visit, dozens of his neighbors painted a dramatically different picture during testimony that evening.

Chuck Baker, owner of Chuck’s Repair Shop was represented among the group of neighbors testifying against the mine.  A couple of days earlier, this sign appeared next to Chuck’s sign out on the highway.  It gives a great impression of what a good neighbor Badger Bluff Sands has been, no?

Thanks Chuck (and all you others).  If I have any auto repairs coming up, Chuck’s going to get my business.  I hope he gets yours as well.

class act

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Testimony OPPOSED to the Starkey request for rezone to “Industrial”

Date:   March 2, 2014

From: Mikey O’Connor (Praag, WI)

To:       Buffalo County Board

Re:       Testimony OPPOSED to the Starkey request for rezone to “Industrial”


Focus on the future: More NEW jobs, not more OLD jobs

I hope you think about the careers of Buffalo County children and deny a rezone application that will put a 19th-century style rail-loading facility in the heart of Buffalo County, focus our economy on mining, and wreck one of the best chances for Buffalo County to compete and win in the 21st century.

Much has been said about all the disadvantages Buffalo County has, and how we need the new jobs that sand mining will bring. But don’t overlook what we have going for us as we prepare our kids (and ourselves) to compete in the worldwide “Information Economy.”

  • Internet Infrastructure: All of Buffalo County has reasonably fast DSL.  That portion of the County served by the Nelson and Cochrane telephone cooperatives has “fiber-to-the-home” – which is the best “future proof” Internet infrastructure in the world.
  • Unspoiled environment: Buffalo County is in the Driftless Area – some of the most beautiful and unique natural habitat in the world.
  • Air travel: Buffalo County is within 2 hours of an international hub airport offering convenient, reliable and diverse travel options, worldwide.

There are more of these attractions (hunting, fishing, boating, etc.), but you get the point. We could focus on developing 21st Century jobs (which, like mine, can be done anywhere there’s good Internet access). We could teach our kids how to compete at a world-class level without leaving their houses, never mind leaving the county.

What do 21st century Information Economy workers want when they’re choosing a place to live and work?  They want a vibrant community, beautiful places and great access to the world. We have all these and more, right now. Many county economic development officers would kill to have the “future proofing” amenities that we can offer here in Buffalo County.

Let’s focus on delivering a positive future, and opportunities for the next generation.

Please vote for 21st century jobs, not 19th century ones.  Oppose the Starkey rezone.

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Testimony OPPOSING SB 632 and AB 816


Mikey O’Connor
Buffalo County Business Owner and Resident
S1287 Wisconsin State Highway 88, Box 38, Gilmanton, Wisconsin 54743

DATE:  March 2, 2014


Senator Thomas Tiffany, 12th  Senate District Chair, Senate Committee on Mining
Representative Mary Williams, 87th  Assembly District Chair, Assembly Committee on Mining
Senator Kathleen Vinehout, 31st  Senate District
Representative Warren Petryk, 93rd  Assembly District Member, Assembly Committee on Mining



SB 632 and AB 816

Dear Senators Tiffany and Vinehout, and Representatives Petryk and Williams:

I am a business owner and resident of Buffalo County, currently under siege by an out-of-state sand-mining company attempting to launch a multi-location frac sand strip mining and rail loading facility here.

I’m also a member of an informal group of people striving to bring order and fair play to the process of siting mines and rail facilities here in the County.  Many of us are farmers and small business owners.  We see the businesses we have worked hard to build threatened by a pell-mell rush to introduce 19th century mining jobs into this region.

Buffalo County is well positioned to expand its economic base by competing on the world stage for 21st century Information Economy jobs – but that opportunity will vanish if the region is hurled back into a 19th century extractive economy.  We are united in the idea that decisions that have such profound impacts on local businesses and residents should be made locally.

  • These bills will harm our ability to bring the awareness and knowledge of local stakeholders to bear on decisions that will impact our health, safety and welfare for decades.  ‘
  • The consequences of your actions will put some of us out of business.
  • And, by destroying the amenities which make this area attractive first-tier information workers, our residents and children will be at a permanent disadvantage in the worldwide Information Economy.

Please vote against these bills.

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Stoddard testimony opposing SB 632 and AB 816

Stoddard1 Stoddard2

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A Win/Win Vote for the Town of Dover

A Win/Win Vote for the Town of Dover


On  February 19, the Town of Dover Board once again asserted its determination to protect the health, safety, and welfare of its citizens, and also its willingness to retain local control of local issues.

The Dover Town Board, by a 2-0 vote, passed a non-metallic mining licensing ordinance, an ordinance that empowers the town to approve or to deny an operating license to any prospective industrial-size non-metallic mining project.  The ordinance does not prohibit non-metallic mining, but it does give to the township “ yes or no” control of any such project. One town board member did not attend the meeting.

The township has been enjoying years of sustained, steady growth as a mixed farming, residential, and recreational community.   As dairy farming has waned in importance, many of the township’s  long-established landowners have adapted to changing economic conditions by dividing larger acreages into smaller, more affordable, home site parcels, as well as by selling sell “forties” or “eighties” to provide access to world- famous Buffalo County deer hunting. This gradual shift in land ownership and land use patterns has worked out to the benefit of all parties concerned–traditional families, newer residents, and hunters.  However, the whole symbiotic relationship has been threatened in recent months by an attempt  to site a huge, 400 acre sand strip mine and wash plant right in the most populous section of the township.

Congratulations to the Dover Town Board! It has spoken loudly and clearly; Town of Dover will both protect its citizens and will keep the Lookout area as premium home-building real estate location—the Town of Dover will control its own future!


Submitted by:

Tim Zeglin

W29086 State Road 121

Independence, WI 54747

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78 Reasons to Deny Glacier Sands Rezone


This is a letter that the Buffalo County Defenders just sent to all the Buffalo County Board members.  You can either read the images on this page, or click HERE to download a PDF version of the file.

78 reasons1 78 reasons2 78 reasons3 78 reasons4 78 reasons5 78 reasons6

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Tips for testifying at the Glacier-sands rezone hearing

Our Zoning Committee Chair laid down the rules for testimony at the yesterday’s preliminary meeting about Glacier Sands’ application for a rezone across from CFC School.  Here’s the long list of things that he instructed people they couldn’t testify about.

“Most importantly we will have only testimony regarding the rezone petition. Speakers must testify to the petition only. Comments about nonmetallic mining reclamation ordinance or nonmetallic mining policies and procedures, critiques of the zoning ordinance, anything about specific mines either permitted or in process, the conditional use permit that this application may evolve into, or critiquing the land resources staff or committee are not acceptable testimonies. ”

If he pulls the same stunt tomorrow here, according to Mr Taylor, are things that you CAN testify about tomorrow.

Glacier Sands – they’re the applicant (they signed the petition)

The landowners – “John & Patricia Starkey”  and “Robert L. Kamrowski”

Grain and sand – are listed as the products that “will be trucked to the site”

Highway 35 and 88 – are listed as the roads the grain and sand will be “trucked to the site via”

Trucks entering the intersection near the school – “Trucks will enter and leave the site off the intersection of USH [sic] 35/STH88″

250 truck loads a day – “The facility proposes to accommodate 250 total loads of sand per day, with approximately 60 trucks running each day”

Loadout facility – mentioned repeatedly

Mine sites – “Sand will come from mine sites near Mondovi, Gilmanton, and Montana”

Dust – the facility will “have fugitive dust controlled by use of dust suppressant and/or water trucks”

24×7 operation – “The facility will have the ability to load sand 24 hours a day, 7 days a week”

Wetlands and waterways – “the proposed project has been discussed with both the Wisconsin Department of Natural Resources (for wetlands and waterways permits)”

The scenic highway – “within the scenic highway easement”

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