REV16194

• Permit No: C1981047
• IBM Index Class Name: Revision
• Doc Date: 7/6/1987
• Doc Name: ADDITIONAL WRITTEN COMMENTS BY ALLEN BROTHERS COAL CO REGARDING BLUE RIBBON COAL COS PARTIAL BOND
• Type & Sequence: SL1
• Media Type: D
• Archive: No

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ADDITIONAL ldRITTh'N COMMENTS BY
ALLEN BROTHERS COAL COMPANY REGARDING

FLUE RIEBON COAL COMPANY'S PARTIAL FOND RELEASE RE~dUEST
(Permit C 81 047)
As a follow-up to the formal conference held in Glenwood
Springs on June 23, 1987 concerning Blue Ribbon Coal Company's
partial bond release request, and Allen Brothers Coal Company
(Allen Brothers) submit the following additional comments.
A. THE CMLRD, Ir GRANTING THE BLUE RIBBON COAL COMPANY'S
PARTIAL BOND RELEASE, WILL:
1. Make irrelevant the meaning and true purpose of
Rule 2.05.5 of the CMLRB Rules and Regulations by permitting
the Blue Ribbon Mining Co. to ignore and not abide by the
dictates of this rule. This has now resulted in B.R.M. Co.
dictating their own reclaiming program to the Allen Brothers
with full disregard to the Allens as owners, and their re-
corded contractual rights and further subfecting the Allen
Brothers to S.R.M. Co. and G.M.P.'s fabricated, seemingly
unending reasons as to why the Allen Brothers were always
wrong or neglectful while they (B.R.M. Co. and G.M.P.) were
always right in their actions.
2. Establish a presidence against rule 2.05.5 by which
it's intended provisons and full purpose may be completely
omitted and ignored by both a mining operator and the CA7LRD
in any future related case.
3. Influence the omitting of the other pertinent rules
of the CMLRD, established to be followed by the mining in-
dustry and decisioned and enforced by the CMLRD. This should
be of high concern to the entire Colorado mining industry.
It is the full intention of the Allen Brothers to appeal
a desision granting the $30,000.00 partial bond release to
Blue Ribbon Mining Co. at this time.
.~
G. H. Allen