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a <br />~~ <br />~O~ <br />~~~ <br />Philip C Wolf <br />Auomey <br />January 26, 1981 <br /> <br />Amoco Minerals Co~pany <br />7000 South Yosemite Streeq <br />P 0. Box 3299 <br />Englewood. Colorado 80155 <br />303-740 5084 i <br /> <br />JAN 2 ? ~gg~ <br />Mr. David C. Shelton, Director <br />Mined Land Reclamation Division <br />State of Colorado <br />423 Centennial Building <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />MINED LAND RECLAMATION <br />Colo. Dept. of Natural Rese~~rces <br />Dear Dave: <br />As you are aware, in response to Mr. Bischoff's letter of December 19, <br />1980 concerning the written request of Empire Energy Corporation for an <br />alluvial valley floor ("AVF") exemption, representatives of Empire, <br />including myself, met on December 24, 1980 with employees members of the <br />Division, including yourself, to seek clarification of certain items set <br />forth in that letter. At that meeting we discussed, among other things, <br />three general areas raised in Mr. Bischoff's letter. The purpose of <br />this letter is to set forth my understanding of what occurred at that <br />meeting and to re-request certain information. <br />The first area of Mr. Bischoff's letter we discussed at the December 24, <br />1980 meeting involved Empire Energy's attempt in its AVF request to <br />demonstrate that its existing and planned mining operation is exempt <br />from certain performance requirements for a defined areal extent. In <br />Mr. Bischoff's letter, the Division recognized that Mines Number 5 and 9 <br />of the Eagle Mine Complex met the exemption requirements but stated that <br />"Sufficient information has not, however, been included (in the AVF <br />exemption request) to demonstrate that mining operations described as <br />the Eagle Number 6, Eagle Number 7, or Eagle Number 8 Mines meet the <br />production or permit criteria." Because the Division made this finding <br />that insufficient data was submitted, at our meeting I requested that <br />the Division detail the material it deems necessary and acceptable to <br />enable it to make such a finding. As I understood it, representatives <br />of the Division agreed to provide me with a detailed written description <br />of such material. <br />The second area we discussed involved the six criteria Empire submitted <br />in its AVF request in support of the areal extent of the exemption. In <br />Mr. Bischoff's letter the Division rejected the need for these criteria, <br />