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ii <br />999 <br />Snell &Wilmer <br />LLP. <br />uw o~lces <br />1200 Seventeenth Saeet, Suite 1950 <br />Tabor Center <br />Denver Colorado 80202 <br />(303) 634-2000 <br />Fax: (303) 63¢2020 <br />Robert D. Comer (303) 634.2015 <br />lntemen rcomet®swlaw.com <br />Mr. Mike Long <br />Division ofMinerals and Geology <br />1313 Sherman Street, Suite 215 <br />Denver, CO 80203 <br />Mined Land Reclamation Board <br />1313 Sherman Street, Suite 215 <br />Denver, CO 80203 <br />RiOENIX. ARRDNA <br />TIxSDtV. ARUDNA <br />atvlrrE, cuauaN[n <br />SALTIAIO:(PT. UTAH <br />Via e-mail and hand-delivery <br />Via hand-delivery <br />Re: NOV # CV 2001-005 <br />Petition for Hearing, Extension of Time to Abate and Response to NOV <br />NOV # CV 2000-010 <br />Supplementation of Pleadings <br />Dear Mr. Long and Members of the Board: <br />This firm represents Powderhom Coal Company ("Powderhom"). Powderhom is a debtor <br />in possession having filed a petition in bankruptcy (Chapter 11) in the United States Bankruptcy <br />Court for the Eastern District of Kentucky. Powderhom's bankruptcy case is administrated with <br />the bankruptcy case of its parent, Quaker Coal Company ("Quaker"), and 18 other subsidiaries of <br />Quaker. <br />On December 14, 2000, Powderhom received a Notice of Violation from the Colorado <br />Division of Minerals and Geology (the "Division") with respect to Reclamation Bond #108486 <br />(the "Bond"), which Powderhom had obtained from Frontier Insurance Company ("Frontier") <br />for its mine located near Cameo, Colorado (the "Powderhom mine"). The DMG based the NOV <br />on a finding that the United States Department of the Treasury had revoked the certificate of <br />authority issued to Frontier pursuant to 31 U.S.C. §§9304-9308. The period to abate the NOV <br />has been extended until May 31, 2001, unless terminated prior thereto. Powderhom responded <br />to the NOV on December 29, 2000 and March 14, 2001, and hereby incorporates those <br />documents and any other documents pertaining thereto in this Response. A hearing on the NOV <br />is scheduled for the May meeting of the Mined Land Reclamation Board (the "Board"). <br />Afember: LEX MUNDI, a global association of ~ndependeni law fvms wish members in <br />the United Slates and 60 caunnies throughout the world. <br />RECEIVED <br />MAY 0 ~ 20D1 <br />~Blrislon of M(nerals end Gsalopy <br />May 4, 2001 <br />Snell & W ilmer is a member o(~Er nnwol, a leading association of independent law firms. <br />