Legislation is pending in the State Legislature for “second passage” of a Constitutional Amendment to transfer 200 acres of Forest Preserve lands in the Jay Mountain Wilderness to NYCO Minerals, Inc. This legislation has strong support from North Country elected state representatives. The Governor supports it and the Department of Environmental Conservation (DEC) is taking an active role stalking for the bill.
There are two big problems with this effort. First, this land swap sets a terrible precedent for the “Forever Wild” Forest Preserve. Second, the bill is riddled with inaccuracies, outright falsehoods, and misstatements.
In New York, a Constitutional Amendment requires passage in two successive Legislatures and then approval by a majority of voters in a statewide ballot. “First passage” for the NYCO amendment was achieved in 2012. A new Legislature in 2013-14 provides the opportunity for “second passage.”
Here are the facts. NYCO Minerals, Inc., started mining in the Champlain Valley in the 1950s. In the early 1970s it opened a mine on Seventy Mountain in the Town of Lewis. NYCO called this “the Lewis mine” and it received one of the first permits from the Adirondack Park Agency (APA) for a 30-acre open mining pit on a 260-acre tract. This permit reported that a series of test bores throughout the tract had found wollastonite of a high grade. For 40 years, NYCO has mined the Lewis mine and through a series of new permits from the APA, it expanded the mine pit to over 80 acres. The west wall of the mine pit borders the Forest Preserve lands of the Jay Mountain Wilderness.
NYCO built and operates a processing plant in the neighboring Town of Willsboro. NYCO trucks tons of wollastonite embedded in rock to this plant where it is separated and processed. Wollastonite is used in various products. NYCO employs around 100 people; many have worked there for a long time.
NYCO started expanding the Lewis mine in the mid-1990s. That meant that it blasted more often and trucked more rock and ore to Willsboro. To get to the Lewis mine, big NYCO trucks operate on narrow, steep and twisting town and county roads. Expansion allowed over 60 truck trips daily, that’s over 120 truck trips up and down these hillside roads. For neighbors, the loud, screeching trucks and the blasting from the mine pit is a constant nuisance; sometimes windows shatter, there are close calls on the roads. The Residents for Responsible Mining formed in the late 1990s and at its peak had over 100 families that tried to intervene in the permit process to protect their homes and quality of life.
NYCO believes that it’s coming to the end of the Lewis mine and wants access to the Forest Preserve along the mine pit’s west wall to extend mining another 6-10 years. NYCO’s surrogates have said this is a do-or-die situation for the mining company.
Yet, NYCO is not banking solely on this amendment. It has invested millions of dollars in its processing plant in Willsboro. It controls a healthy share of the world’s wollastonite market. By all accounts the company has done well in the Champlain Valley.
In 1997-1998, NYCO went through a full-blown APA adjudicatory public hearing for a brand new mine, the Oakhill mine, two miles from the Lewis mine. At Oakhill, NYCO owns 455 acres and was permitted to begin with a 30-acre mining pit, which subsequent permits saw expanded to 50 acres. NYCO built its own private access road to Oak Hill that enters directly onto Route 9. There are many fewer nuisance issues with neighboring residents at Oakhill than at the Lewis mine.
At the time it secured the initial Oakhill permit, NYCO said it only had 3-5 years left at the Lewis mine. It pressured the APA to give it everything it wanted, with minor concessions to area residents. NYCO stated emphatically that it would not operate two mines more than a few years as it opened the Oakhill mine and phased out, closed, and then reclaimed the Lewis mine.
In 2002, NYCO received a new permit for the Oakhill mine from the APA which stated that it had signed a 10-year contract with Graymount, a major supplier of crushed stone for highway construction and other purposes. NYCO didn’t just take a page from Tom Sawyer, it took the whole book; NYCO got paid by Graymount to rip apart Oakhill and remove the overburden to expose the wollastonite deposits. Graymount has a processing plant a short distance away on Route 9. This deal remains in place today and apparently has worked well for both companies. The APA has given NYCO a series of new permits authorizing greater volumes of the “aggregate” overburden to be mined and removed by Graymount on Oakhill. Now, more than 180,000 tons annually are removed from Oakhill.
NYCO also continued to operate the Lewis mine well beyond the 3-5 years it claimed it had remaining when it pressured the APA to secure the new Oakhill permit. The Lewis mine reserves may now, 15 years after the original Oakhill permit was awarded, be running out.
In 2006, NYCO submitted a “25-Year Plan” to the APA. NYCO stated that it would wind down the Lewis mine by 2015 and have the Oakhill mine up to maximum capacity the following year in 2016. Moreover, the report stated that the wollastonite NYCO would extract from Oakhill was higher quality, making its mining activities more efficient.
Simply put, NYCO has been planning for how to sustain its operations for a long time. NYCO has been working for a long time to make sure it has all the wollastonite it needs and that there will be no interruption in supplying its customers.
Lets look the two big problems with the proposed NYCO Constitutional Amendment. Lets start with the bad precedent.
1. The proposal is totally contrary to “Forever Wild,” the only Article of the Constitution adopted unanimously by the delegates to the Constitutional Convention of 1894, the first 54 words of which remain unchanged to this day.
2. The proposal is totally contrary to the consistent theme of the few amendments enacted since 1894: each was limited in scope; each was in furtherance of a public, not a private purpose; and, each resulted in a net benefit to the Forest Preserve.
Past amendments include the expansion of a town cemetery in Keene, expansion of a public airport in Arietta (which was done twice), needed improvements for a public water supply for the Raquette Lake community in the Town of Long Lake, minimization of public utility routes and impacts from the Stark Falls dam to the Village to Tupper Lake. The only other Constitutional Amendment that involved a private benefit was the Perkins Clearing land swap between the DEC and International Paper Company, where a checkerboard series of intertwined holdings were swapped so that each side had a large contiguous block to manage.
The proposed NYCO proposal breaks with historic precedent because it would be the first Forest Preserve Constitutional Amendment to be undertaken for private commercial gain rather than for a public municipal purpose.
Lets turn now to the many misstatements and inaccuracies in the legislation that supporters wrote to support their case.
The bill language and bill Justification include numerous misstatements, while omitting critical information. The Bill Justification simply does not accurately portray the situation.
The Bill Justification states:
“The Lewis mine produces 60,000 tons of wollastonite annually – a little more than 8% of the annual worldwide production. However, NYCO’s mine is approaching the end of its pit life because the wollastonite vein extends onto adjacent Forest Preserve land.”
This statement is misleading. It makes no mention of the fact that NYCO has secured numerous permits for another mine and has been working in that mine for more than a decade to prepare it for wollastonite mining. Why is the existence of the Oakhill mine omitted?
The Bill Justification also states:
“NYCO mines wollastonite on a 260-acre tract in the Town of Lewis, Essex County, with processing facilities in Willsboro, Essex County. It has 95 full time employees and has an annual payroll of $4,600,000. It has 63 vendors within a 100 mile radius and spends $2,300,000 locally per year. It pays $260,000 in local taxes.”
This statement is misleading too. First, as of January 2013 (Adirondack Park Agency permit 99-9II), NYCO’s Lewis mine was an 89.9-acre open pit mine area (54 acres developed) on a 260-acre tract. The Oakhill mine, less than 2 miles away, was originally permitted as a 31-acre open pit mine site on a 455-acre tract. The mine site has been expanded since 2002 and is now over 50 acres in size. NYCO owns and manages two mines with over 700 acres in the Town of Lewis. Again, why is the existence of the Oakhill mine omitted?
The Bill Justification also states:
“Indirect economic benefits to the area are considerable. Thus, the closure of the Lewis mine would have devastating effects on the local economy. Ninety- five full time jobs and significant tax revenue would be lost in one of the more economically depressed area of the State.”
This statement is also misleading. NYCO isn’t going anywhere. In 1998, NYCO received its first permit for a new mine. It has built that mine. NYCO’s own 25-Year plan submitted to the APA in 2006 called for a gradual transition to Oakhill where NYCO estimates there enough wollastonite for at least 16-21 years. NYCO also owns 455 acres around the Oak Hill mine, which contains wollastonite reserves, far beyond the current mine pit of 54 acres.
Any statement in this bill that NYCO will leave the state if this Constitutional Amendment is unsuccessful is simply false. NYCO’s future is not contingent on this proposed Constitutional Amendment. Its “25-Year Plan” submitted to the APA detailed its plans to transition from the Lewis mine to the Oakhill mine.
NYCO has received a string of permit amendments and new permits for the Oakhill mine to build a new access road, increase the amount of aggregate its subcontractor removes, conduct late season mining activities, build wetlands, and an assortment of other mine related activities. NYCO has made a major investment in building and readying the Oakhill mine for wollastonite extraction. The Oakhill mine is a fully functioning mine. NYCO has been planning for years to transition wollastonite mining activities to Oak Hill.
NYCO, and area political representatives, put enormous pressure on the APA in 1998 to approve the Oakhill mine permit. If it did not get Oakhill, they would close or stop investing in the area, went the song back then. Now the song has changed to NYCO will close or stop investing without the Constitutional Amendment. This is not a legitimate argument. Why does the bill threaten the closure of NYCO’s operations if the Constitutional Amendment fails when NYCO’s long-term plan and permits reveal this to be a fabrication?
These threats make it seem like NYCO doesn’t know what it’s doing. To the contrary, NYCO seems to have done a very good job of planning its future to make sure there is no interruption in the supply of materials to its customers. In fact, the overheated rhetoric of the bill justification stands in stark contrast to how deliberately and methodically NYCO has operated to secure its business.
The Bill Justification also states:
“NYCO’s main competition comes from China, India, Finland, and elsewhere in the United States. In order to remain competitive, NYCO must mine as efficiently as possible and ensure customers of long-term reserves. However, recovery from the Lewis mine is now low, as NYCO approaches the end of pit life.”
This statement is not accurate. NYCO’s 2006 “25-Year Plan” states that the percentage of wollastonite at the Oakhill mine is higher than the Lewis mine and that the supply will last at least 16 years, if not longer, at Oakhill. It is simply not an accurate statement that NYCO will suffer in efficiency or will not have reserves if it has to transition, as it has long planned to do, from the Lewis mine to the Oakhill mine. Why does the bill fail to mention NYCO’s data that wollastonite is of a higher quality on Oakhill? Why does the bill fail to mention that NYCO has plentiful reserves at Oakhill?
The Bill Justification is riddled with inaccurate and misleading statements that are contradicted by NYCO’s “25-Year Plan” and by the dozens of APA and DEC permits that NYCO has secured for both of its mines in the Town of Lewis.
There are two benefits to NYCO that I can see for wanting to continue its operations at the Lewis mine by gaining access to the Forest Preserve. First, it delays restoration and remediation costs of the Lewis mine site under the Mine Reclamation Act. That would likely cost a pretty penny and it’s understandable that the company would want to delay these expenses. Second, NYCO seems to like operating two mines simultaneously. There must be an economic benefit for them to do so.
But these benefits to NYCO’s bottom line don’t outweigh the ruinous precedent for the Forest Preserve.
If this Constitutional Amendment goes through and is approved by the voters in a public referendum it means that there is no place in New York beyond the reach of commerce. It means that there is no place beyond the grasp of various corporations and their political bidders.
It means that there is no place in New York that is truly forever wild.
Editor’s Note: Here’s a copy of the bill sponsored by Senator Betty Little in the Senate and Assembly member Dan Stec in the Assembly. Here’s PROTECT’s Memo of Opposition. Click here for aerial pictures of the two NYCO mines.
“This legislation has strong support from North Country elected state representatives.” No surprise there. Is there any way to discover what campaign contributions, if any, have been made by NYCO to these legislators?
[…] a much more detailed article posted on the Adirondack Almanack website about the NYCO […]
You say it is a “swap”? A swap for what? I missed that part.
Didn’t we need to amend the constitution for the Olympics?
I agree that there are some inconsistencies between the justifications for this land swap and NYCO’s actual statements and operations. I do not, however, see that this either sets a bad precedent or that the deal isn’t good for the Forest Preserve in the long run. Peter fails to mention that NYCO must pay for the purchase of additional land to add to the Forest Preserve and that the swapped land goes back to Forest Preserve when the mining is done. Furthermore, this is hardly the only amendment to Article 14 that has benefitted an private corporation. The Perkins Clearing land swap was a huge benefit to a private corporation, i.e. International Paper; and the power line relocation benefitted a private company, National Grid (also a “foreign” company) by shortening the length of new line they had to build.
This amendment will increase the size of the Forest Preserve, keep a local business employing people for the foreseeable future, and in my view not in any way lessen the threshold for any future amendments.
Let’s get this right: NYCO is NOT a local company. It is a subsidiary of an offshore corporation based in Athens, Greece. We give them a piece of the Forest Preserve, they give us back a landfill with seedlings planted on top, and we sing and rejoice how the park is so much better.
Well I am sure the Greeks working there appreciate the jobs? And I am sure the taxes they pay to schools back in Athens also appreciate the money!
The land goes back to the Forest Preserve after it’s been raped! The state won’t even consider other open pit mine areas for addition why would they want this one?
The trees are getting Big in the High Peaks. Why not swap out with Ward lumber so they can make more money? Does this sound ridiculous?
Paul, no constitutional amendment was actually needed for the 1980 Olympics. A few years later, an amendment “ratified” the widening of a few sections of trail at Whiteface beyond the original 80-foot width prescribed in the 1940 amendment. There also had to be a minor adjustment of the boundary of the “Intensive Use” area at Mt. Van Hoevenberg to allow for mechanical grooming on one trail not originally included (due apparently to a mapping error) in the basic trail system.
As for the comment about Ward Lumber, the Perkins Clearing swap did give IP some big trees that had been growing on Forest Preserve. If you looked at the before and after map, however, you would see that the Forest Preserve gained a great deal of new, contiguous parcels that significantly enhanced and protected the eastern approach to the WEst Canada Lakes Wilderness Area.
As Barbara McMartin acknowledged in several of her writings, the Forest Preserve was acquired very haphazardly. Clearly, most of what has been acquired should remain, but I feel there is definitely room for more “tweaking” around the edges to shorten its boundaries and add desired lands even if it means occasionally giving up a few acres here and there.
Tony, thanks for the info.
Tony, do you know how much the Forest Preserve is worth? Priceless!
tragedy of the commons
My problem with the :swap” is simply how little NYCO will give compared to what the state will get. If NYCO was footing the bill for Follensby or a similar property then maybe. I would hope the Governor and Legislature won’t approve this without the Park getting a much better deal.
For a full understanding of the debate here, I think it’s important to note that the Adirondack Mountain Club also supports this land swap.
The group’s board of directors voted to support the NYCO project last year.
“For 90 years, the Adirondack Mountain Club has been dedicated to protecting the Adirondack Forest Preserve and the constitutional language that guarantees it remains forever wild,” said ADK Executive Director Neil Woodworth.
“Years of hard work and negotiations went into crafting these amendments to ensure that New York will end up with more-valuable recreational and scenic lands for public use and enjoyment.”
–Brian, NCPR
The ADK is not an environmental organization yet are often brandished as such. They are no different than a runners organization or a snowmobile club. They create subsidiary organizations like the 46ers that go out of their way to trample the environment. They just don’t get the bum rap like snowmobiles because they only burn fossil fuels to get to their access points.
I think most folks understand that ADK is not an environmental organization. They run two hotels in the middle of the high peaks.
ADK takes an active role in offsetting the impacts of the recreation they promote- in fact, it’s safe to say that they’re more serious about it than any other Adirondack-focused advocacy group in existence. To suggest they are “not an environmental organization” and imply hypocrisy is to admit to ones own shallow and selective view of the history of environmental advocacy in the Adirondacks, and the critical role ADK has played over the years. Additionally, it’s also safe to say that the educational resources and guidance ADK has provided over it’s long history have helped forge more environmentally-minded and conscientious backcountry visitors than any other Adirondack-focused advocacy organization, yet you would compare it to a runners club? Get real, Alan. No one wants to experience the Adirondacks through just pretty photos, and if you only bike and walk to every trail-head all the time, congratulations- my hats off to you. But where does the hypocrisy stop?? how can Protect! be an environmental organization? I saw Peter Bauer drive a car once! Come on, this is foolish and really contributes nothing. I get the sense you must get to spend an awful lot of time in the woods- but I suspect that it’s probably alone.
The ADK has had some good programs for sure, Ketch’s work and the summit steward program are great! I am a member and well aware of the constituency. All of their decisions are based on what is best for hiking activities. They push for more and more trails. Many members have been ticketed by the DEC over the years for illegal cutting of trails. I am not saying they are bad, but they put their activity before the environment just like snowmobile clubs. They are no different than a runners organization. They like to highlight an athletic pursuit. Green groups like the ADK Wild, Protect and the Council are the true environmental advocates for the park. I am not saying the ADK is bad I just do not think it is appropriate they are brandished as an environmental organization. They are hikers only.
Oil companies take an active role in offsetting the impacts of spills but no one considers them green.
I would love to see what NYCO’s “reclamation” of the present mine would look like before voting to allow another horrible scar on the landscape — visible from Lake Champlain.
Brian, why do you feel it’s important to highlight ADKs position on this ridiculous proposal. Never in the history of the Forest Preserve has an exception to Article 14 been so much as considered for a private entity. This is no time to start. Not only does Peters article very clearly lay out the misrepresentations made by this multi national company but also the bills sponsors, it also appropriately alerts readers to the fact this proposal will benefit the company and nobody else. It is not a public need or emergency. It should be denied.
“Never in the history of the Forest Preserve has an exception to Article 14 been so much as considered for a private entity.”
Lily, did you read Tony’s comment above?
From this article I don’t know if this is a good idea or not. What people need to make informed decisions is ALL the information. Peter doesn’t even bother to tell us what the state would get in return for the swap. Why do you have a problem with Brian giving us some more information. People can judge for themselves if ADK support is useful or not.
Lots of good comments. Thank you.
A few responses from the top.
Phil, yes state BoE record show at least one recent NYCO contribution to Sen Little for $2500. System doesn’t let one search by company.
Paul et al, as to the swap and info, I refer to this in the piece to a land swap and to an exchange, but nobody knows what’s to be exchanged? how much? where? None of that has been made public.
Tony, yes Perkins Clearing is the closest Constitutional Amendment we have where a private benefit resulted, but it also provided, as you note, a real public benefit. I don’t think this is a healthy precedent for the Forest Preserve. We give it to NYCO now and in 10 or 15 years they’ll want more and the same arguments will be used.
Bill, Alan, Tyler — all good statements that I cheer!
Brian — this article was not meant to show who is for and who is against and why (you can do that piece). It was an effort to bring to light big pieces of this story that none of the supporters had brought out, whether DEC or in the Legislature. There are many in the Assembly who feel they were hoodwinked. Also, I do not believe that the local media fully investigated this issue, the feelings of impacted local residents, the existence of two mines, the series of APA permits, the BS in the legislation.
Lily — agreed. This is a bad idea.
Paul — see my comment to Brian. The other groups are quite capable to speak on their positions. It would not be appropriate for me to speak about where other groups stand.
Peter, If it keeps leading to no net loss in FP that doesn’t seem like a ruinous outcome?
Paul, Peter’s contribution here isn’t much different than NYCO’s public portrayal of their business prospects. Both are entirely predictable, and can only be taken at face value. So in a certain way, I suppose I would agree with Peter’s assessment. More importantly, ADK deserves credit for taking a hard look at this proposal and coming down on the side of growing the forest preserve in a big way, and understanding the critical importance of preserving jobs and economic stability locally. From my own understanding of the swap, ADK made the right call on this one. Protect! may snag a few misinformed members out of this by making some noise now(see above), but ADK really deserves credit for being a part of this very important and valuable contribution to the forest preserve AND the Adirondack Park in the long run.
does this grow the FP in a big way?
No. You can’t call the proposal a big net gain of FP. That is completely false.
If Forest Preserve is priceless (as stated above) then a net gain may be a good thing? To me it depends on what land is being given up, and what land is added. For example: If we lose 200 acres of unspectacular land that no one is using, and gain 2000 acres of land that provides spectacular features that people want to use then I think it is a good swap. If the opposite is true, then it would not be a good swap.
Our state constitution should be respected, but it is not a religious document. There is a process for amendment. This issue is going through that process now.
Agreed but the amt of money they are offering to put up to purchase new “FP” is not enough.
Alan, slow down. If you read the comment you will see that it was a question. Not a statement. The fact that it started with “doesn’t” and ended with one of these “?” should have clued you in.
I think there are many good “swap” opportunities that could be a large net positive for the Forest Preserve. Most developers are not terribly interested in things like wetlands. But as a state we want to preserve these as much as possible. You give me your wetlands and I will give you my not so biologically diverse and scarce upland land for development. Everybody wins.
Tell Governor Cuomo there are guns involved and he will reject it in an instant
What is only alluded to in the above comments is that NYCO will pay for a significant amount of new, permanent Forest Preserve in exchange for the 200 acres needed to expand the mine. Then, at some point the 200 reclaimed acres is returned to the Forest Preserve. While you can try to attach sinister motives to a Greek-owned company, NYCO operates locally with local employees. British-owned National Grid also operates locally with local employees, and they received the blessing of the environmental community for the constitutional amendment that allowed them to shorten their power line. I see both amendments, one passed and one pending, as appropriate ways to ultimately strengthen acceptance of the Forest Preserve and thereby keep well at bay attempts (and there certainly have been some) to seriously weaken the forever wild protection of the nearly three million acres now included in the Forest Preserve.
I have no problem with the company just selling wilderness to the highest bidder for economic gain. If they were offering to buy something like follensby yes but the amount of money they are taking is not significant enough in my opinion to sell out Forever Wild.
Again the land we want to add to the Forest Preserve (things like wetlands and other areas that are basically no good for development) is stuff that doesn’t often have a big price tag since there isn’t much of a market for it. But we should make sure they are giving us enough. Tony makes a good point. In the end you get it all back anyway. Just have to be a little patience and think long-term.
Firstly, it is my understanding that NYCO now employs less than 35 people at it’s Willsboro plant. I live with the consequences of NYCO’s prescence in Willsboro everyday!You can’t imagine what it is like to have to listen to a constant droning sound 24/7 emitting from the plant & I live about 3-4 miles away from it. It’s hard to even hear the birds singing when the wind is coming from the south. If I go for a paddle on Willsboro Bay, the bay seems to magnify the sound & you just can’t escape it. Also, be forewarned if you are driving into Willsboro on Rt. 22 and see what appears to be smoke up ahead, it is actually the dust cloud over the Willsboro plant. Read up on Wollastonite. Breathing it’s fibers on a daily basis is not good for one’s health. Their storage area has been expanded so much that it is pouring over into the surrounding wetlands & is practically all the way up to Fish & Game Road. I have contacted NYCO on several occasions & explained to them about how far away the constant droning can be heard. They don’t seem to be the least concerned. Be forewarned if you ever attempt to drive through Reber on a day when their trucks are hauling from the Lewis mines you have to contend w/these monsters bearing down on you at higher rates of speed than the posted limits.This company makes no attempt to be a good neighbor to the residents of Willsboro & I see no benefit in making accommodation for them to continue wreaking havoc & destrruction on the area. Have you ever seen their mines from surrounding hills or mountains? They are horrific scars on the mountainside. What will they give back? Why would anyone want it?
One year ago, Adk Wild and other groups discussed the NYCO situation and the Constitutional amendment it seeks with NYCO president Peter Goodwin. Mr. Goodwin was candid and forthcoming. He confirmed several assertions in Peter Bauer’s essay: Yes, NYCO would like to exploit wollastonite veins on Forest Preserve Lot 8 adjoining its current mine pit through a land exchange because it would strengthen NYCO’s competitiveness and efficiencies to do so, but if they were not permitted to do so the company would not leave town, but move its full operation to its permitted mine at Oakhill several miles away. Secondly, the company estimates that the quality of the Oakhill mineral is every bit as good as below Lot 8 Forest Preserve, but that there is a lot of work and cost to remove the trees, soils, rock above it. Bauer’s essay suggests that the crushed stone group, Graymount, has done a lot of that overburden removal work already. Not being aware of this at the time, none of us questioned Mr. Goodwin about it. Overall, then, Peter Bauer is right when he asks why those in state government pushing the constitutional amendment and land exchange do not bring up the nearby Oakhill which has significant wollastonite reserves that would keep area NYCO employees busy for many years to come. He is also right when he says that there is quite a bit of misleading information disseminated by amendment sponsors about the company’s economic prospects for remaining in Essex Co. I believe NYS Dept. of Environmental Conservation is pushing the amendment for opportunistic reasons, to gain significant new tracts of Forest Preserve for the Jay Mountain Wilderness Area in exchange. While we fully support the objective of identifying and evaluating land which might expand that Wilderness, that goal should be accomplished through the state open space plan and use of the environmental protection fund, not a land exchange merely for the cost-cutting convenience of an abutting mining company. Adirondack Wild: Friends of the Forest Preserve opposes this constitutional amendment because it fails to meet our test of clear public benefit.
I have property very close to the mine off of wells rd. I haven’t been able to find in any of the articles or in the legislation exactly where lot 8 is. Does anyone know where I can find that?
Thanks