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% , /.. <br />III IIIIIIIIIIIIIIII ~~-- ,< rr•l~~!'' .~ - <br />r.~ r <br />eca~~~ tise~~ cc~~flra'ticr~ f ~~.t ~ S ,~-_ , <br />executive ollices • suite 900 • three park central • 1575 ara pahoe • denver, Colorado 80202 • (303) 623-8317 <br />April 15, 1981 <br />o ,~n~~~~ <br />Mr. Gerald Magnuson ~,.( ~~~ <br />APR 1 ? 1981 <br />Alternate Regional Coal Team Chairman •j: <br />Eureau of Land tanagement L~I~!___ ~~ <br />Utah State Office L'EF.;rrlean; ~r r;ar~~,:.~ i,c;,.~,..w <br />136 East South Temple <br />Salt Lake City, Utah 84111 <br />Re: Pinnacle Tract Lease Sale - Proposed Lease Form <br />Dear Mr. Magnuson: <br />This letter is written to express the strong objections <br />of energy Fuels Corporation ("Energy Fuels") to portions of <br />Section 6 and 31 of the proposed Coal Lease C-24220, As you <br />know, Coal Lease C-29220 will be offered for competitive <br />lease sale on April 30, 1981. <br />In general, Energy Fuels objects to those portions of <br />Coal Lease C-29220 which, in its view, seek either to alter <br />the legal rights of the prospective lessee through contractual <br />lease provisions or to empower the Bureau of Land Management <br />("BLid") or the Colorado Division of Wildlife ("DOW") with <br />approval powers which neither the BLt•1 nor DOW would otherwise <br />possess in the absence of the lease provisions. It is the <br />hope of Energy Fuels that the specific objections sat forth <br />below will be seriously considered by the Green River-Hams <br />Fork Regional Coal Team prior to the April 30, 1981 lease Sale <br />and that Coal Lease C-29220 will be altered in accordance <br />therewith. <br />In the comments which follow the objectionable provision <br />will be identified, followed by a brief discussion of the <br />objections of Energy Fuels to that provision. <br />Lease Provision - Section 6. PRODUCTION ROXALTY: <br />"...The royalty rates provided in this section shall <br />not be subject to revision except in the course of <br />lease readjustment." <br />OBJECTION: The effect of this provision is that the royalty <br />rate set forth in the lease may be revised only on the 20th <br />year after the effective date and on each 10th year there- <br />after, in accordance with Section 23. Energy Fuels is <br />