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ENFORCE21612
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ENFORCE21612
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Entry Properties
Last modified
8/24/2016 7:31:39 PM
Creation date
11/21/2007 10:00:22 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981025
IBM Index Class Name
Enforcement
Doc Date
1/29/1981
Doc Name
SNOWMASS COAL CO NOV 80-41 80-42 AND 80-43
From
FRIEDMAN HILL & ROBBINS
To
MLRB
Violation No.
CV1980043
Media Type
D
Archive
No
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FRI1~;DMAN. 1-IILL 8c BOBBINS <br />:~rrDHNr~'s AT i.:~W ~CE~-G~ <br />DAVID W. ROdHINS -=U Etl111'I',\HLE HIIILDINU <br />H OdF.RT F. HILI. )eU sF\'ENTYENTII STI2FHT <br />ALAN il. FkIHDMAN UL\'l'F; R. COLOI2AU0 BU111e ,1q~~'9: Q9/2yDINU <br />HAHEN A. TOFIA OF c <br />ar~~ eve-nauo MMFU LAND <br />COIq ~ ~A~L4TION =COAL' <br />1 ~ NATURAL RESOURCES <br />January 26, 19II1 <br />Mr. James Kent <br />Assessment Hearing Officer <br />Mined Land Reclamation Board <br />423 Centennial Building <br />1313 Sherman Street <br />Denver, CO 80203 <br />Re: Snowmass Coal Company: Notices of <br />Violation 80-41, 80-42, and 80-43 <br />Dear Mr. Kent: <br />With regard to the assessment conference which you <br />held on January 20, 1981, concerning the above-referenced <br />NOVs, I would like to raise several matters with you for the <br />record. <br />First, as I indicated to you at the time of the <br />conference, it would seem most appropriate to provide the <br />company against whom the NOVs have been issued with copies <br />of the staff determinations concerning civil penalty assess- <br />ment. As you are aware, we were first able to review Mr. <br />Herron's and Mr. Liddle's determinations concerning penalty <br />assessment at the time of the conference, although Mr. <br />Herron's memo on the subject was dated December 22, 1980, <br />and, from comments made at the conference, I presume that <br />Mr. Liddle's was prepared at approximately the same time. <br />As I think we all agreed, there is no particular reason to <br />withhold this information from the company against whom the <br />NOV has been issued, and it most definitely would give a <br />better appearance of fairness and due process with regard to <br />the assessment conference if that material has been made <br />available to the company at some time previous to the <br />conference. <br />Second, I would very much appreciate it if in the <br />future the staff could delineate which of the factors pro- <br />vided in the regulation (5.04.5(2)(d)) is being relied upon <br />
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