Colhoun vs RM Lumsden $32,000

PLEASE REFER TO: Barton Soroka
Email: bsoroka@grj.ca
July 16, 2021
Without Prejudice
Attention: Ryan Nagel
Dear Sir:
Re: Q.B.G. 1157 of 2019
Our File #15294.001 BPS
Your client has requested that the RM consent to the continued removal of aggregate from his land
in order to continue with remediation, per the Skynorth Gravel Pit Reclamation Plan. Prior to
providing authorization, the RM requires additional information from your client.
Costs
The RM has incurred significant legal costs over the multi-year struggle to have your client comply
with the Orders that have been made. The RM is requesting that your client agree to pay $32,306
to the RM as compensation for the costs incurred in enforcing the Orders.
Inclinometers
Your client has been clear from the beginning that the work he is doing is to prevent
sloping/slumping and/or danger related to the incline(s) on the land. As such, the RM is requesting
that the reclamation plan include the installation of inclinometers to continue to monitor this area
of concern. An engineered inclinometer design will be forwarded to the RM for approval. The
design will include a recommended schedule for testing. Test results will be immediately shared
with the RM as well as potential land purchasers.
Contact Information
Phone 306 790 3190
Email bsoroka@grj.ca
Address 1914 Hamilton Street #700 Regina SK S4P 3N6

2
Detailed Plan
Please confirm the specific area proposed for remediation. The March 2021 ‘Skynorth 2020
Gravel Pit Reclamation Plan’ does not clearly specify the area intended for remediation.
The RM is requesting that your client provide a timeline of extraction. This timeline can be based
on a start date of August 15 th , 2021 for reference. The RM further requests information on who
will be completing the extraction and what will be done with the extracted aggregate. The RM
prefers that the extraction be done by a 3 rd party to ensure the safety of the land in the future.
Road Maintenance Agreement
Your client will be required to enter into a Road Maintenance Agreement with the RM prior to
removing extracted gravel.
Conclusion
We look forward to your response to the above noted concerns.
GERRAND RATH JOHNSON LLP
Per:
BS
CC:
Barton Soroka