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r ~ ~~~ ~~~~~~~~~~~~~~~~ ~,~ STt~TE Or LC~~v~v~~~~ Roy Romer, Gove DEPARTMENT OF NATURAL RESOURCES MINED LAND RECLAMATION DIVISION FRED R. BANTA, Director October 10, 1989 Ms. Sandra Pautsky Pueblo Coal, Inc. 400 First Wational Building Wichita Falls, TX 76301 Re: Carbon Junction Mine Permit Renewal, File No. C-82-054 Dear Ms. Pautsky: We received your letter of September 15, 1989 which contained a recalculated reclamation cost estimate as well as an explanation of Pueblo Coal Incorporated's (PCI) financial situation, The reclamation cost estimate as presented in the September 15, 1989 letter is not acceptable for the following reason. The calculations were based on the assumption that Pueblo Coal, Inc. would be doing the reclamation with their own employees, thereby reducing wage costs and eliminating profit and job foreman costs. These assumptions are not in compliance with Rule 3.02.2(1) which states: "The amount of the bond shall be sufficient to ensure the completion of the reclamation plan if the work had to be performed by the Board, through independent contractors, in the event of forfeiture." As we have indicated in previous correspondence, we cannot agree to an.y further renewal extension until an adequate surety has been provided. Consequently, the Division will issue a recommendation to the Colorado Mined Land Reclamation Board (tne Board) that the permit renewal application be denied. A formal puplic hearing on the recommendation will be scheduled for the December 13, 1989 Board Meeting. We will review an.y additional revised reclamation cost estimate submitted prior to that date. Please contact me if you have any questions, Sincerely, ~~~~G~-~ Michael B. Long Coal Program Supervisor MBL/ern cc: Dan Mathews, MLRD Mike Savage, MLRD Jim Hendricks, PCI 0342E 215 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567