DSHW-2025-001185

DENTONS DURHAM JONES PINEGAR P.C.
Bradley R. Cahoon (5925)
Tyler R. Cahoon (16412)
Cole P. Crowther (16432)
111 South Main Street, Suite 2400
Salt Lake City, Utah 84111
[phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Petitioner Promontory Point Resources, LLC

BEFORE THE EXECUTIVE DIRECTOR OF THE UTAH DEPARTMENT OF
ENVIRONMENTAL QUALITY AND THE DIRECTOR OF THE DIVISION OF WASTE
MANAGEMENT AND RADIATION CONTROL

In re matter of:

Promontory Point Resources, LLC
SW416

REQUEST FOR APPOINTMENT OF
ADMINISTRATIVE LAW JUDGE

By Promontory Point Resources, LLC

November 5, 2024

Pursuant to Utah Code § 19-1-301.5 and Utah Admin. Code R305-7-104(2) and R305-7-
206(2), Petitioner Promontory Point Resources, LLC (“PPR”) hereby requests the appointment
of an Administrative Law Judge (“ALJ”) in the above captioned matter. PPR filed a Petition for
Review (“Petition”) on November 5, 2025.
The Petition requests review and remand of a clearly erroneous Final Permit Order dated
October 7, 2024 (“Order”) by Director Douglas J. Hansen of the Division of Waste Management
and Radiation Control of the Utah Department of Environmental Quality.
The Order incorrectly denied PPR’s commercial Class V permit application to change its
existing for profit in-state Class I landfill to a commercial landfill.
No other party has requested the appointment of an ALJ in this matter.
Accordingly, PPR respectfully requests that the Executive Director appoint an ALJ to
conduct a special adjudicative proceeding of PPR’s Petition.
DATED this 5th day of November 2024.
DENTONS DURHAM JONES PINEGAR P.C.

/s/ Bradley R. Cahoon
Bradley R. Cahoon
Tyler R. Cahoon
Cole P. Crowther

Attorneys for Promontory Point Resources, LLC
1
SL_7250678.1
CERTIFICATE OF SERVICE
I hereby certify that on November 5, 2024, a true and correct copy of the foregoing was
served on the following as indicated:
Executive Director Kim Shelly
Department of Environmental Quality
195 North 1950 West, Fourth Floor
Salt Lake City, UT 84116
Via email: [e-mail]

Craig Anderson
Office of Attorney General
Environmental Division
Utah Attorney General’s Office
195 North 1950 West, Second Floor
Salt Lake City, UT 84119
Via email: [e-mail]
Via email: [e-mail]
Director Douglas Hansen
Utah Department of Environmental Quality,
Division of Waste Management & Radiation Control
195 North 1950 West, Second Floor
Salt Lake City, UT 84116
Via email: [e-mail]

Administrative Proceedings Records Officer
Environment Division
Utah Attorney General’s Office
195 North 1950 West, Second Floor
Salt Lake City, UT 84116
Via email: [e-mail]

/s/Carol MacKay

Raymond Wixom
Office of Attorney General
Environmental Division
Utah Attorney General’s Office
195 North 1950 West, Second Floor
Salt Lake City, UT 84116