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<br /> <br />Mr. Dean Massey <br />Mr. Richard Mills <br />April 18, 1980 <br />Page 3 <br /> <br />In reviewing my records, I see T did not have the <br />comments from the Colorado Division of Water Resources, nor <br />did I have the specific response which Tommy Raye references <br />as Exhibit "E" to his letter of May 18, 1978. <br />I think the permit was originally submitted in accordance <br />with the requirements of Rule 2 of the Rules and Regulations <br />for the Mined Land Reclamation Board as set out in 2 CCR <br />407-1 at Rule 2.11(7), which we must acknowledge were <br />considerably more open than the provisions of 30 CFR 715.17. <br />In any event, it does appear that a determination was made <br />by the MLRB that neither surface nor ground water monitoring <br />would be required in the course of our operation. <br />As you know, we have already been in contact with Rick <br />and two other specialists within your section for the purpose <br />of getting started on baseline data for the permanent <br />application. At this point, we feel that our existing <br />operation has been exempted from the requirements now being <br />imposed by OSM. We also feel that the compliance with OSM <br />requirements at the same time that we are trying to develop <br />through appropriate experts the necessary baseline data for <br />our permanent program is overly burdensome, duplicitous and <br />will unnecessarily complicate our situation. <br />I have advised OSM in writing of our objection to the <br />two violations issued. Any assistance which your department <br />could render to us, either through me or by direct contact <br />with OSM to verify the facts which I have asserted in the <br />first part of this letter would be much appreciated. <br />MLK:jf <br />cc: Mr. Donald Mallory <br />Mr. William J. Ryan <br />Sincerely yours, <br />MARCH, MARCH, MYATT, KORB`/r~ <br />& CAR ~~{ - / !/~/,///~~ <br />i <br />~G~' "" C!/// <br />By. <br />