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Colhoun vs RM Lumsden $32,000

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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

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