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£ent By: Tom Kennedy PC; • 970 72B 9439 <br />Aug-c"3-~ 4:OBPM; Page 2 <br />a <br />• The La\~' Offices of <br />' •l~homas G. Kennedy, P.C. <br />-: 5 East Cn;erado :~~ c.. Smlts 3 b S <br />Yon Office Bay 30F1 <br />Telluride. C.loredo Flli~-3051 <br />Thomas G. Kennedy, Voict: (970) 728-2424 <br />.4dmiaed in Colorado and ~lazyland raz: (970) %28-93.19 <br />Email: il:l~~..~a nni.net <br />August 33, 2000 <br />HA.'vD DELIVERED <br />Steve Zwick, Esquire <br />San Miguel County Artomey <br />333 W. Colorado .4ve. <br />Telluride, CO 81435 <br />RL-: Pathfinder <br />Dear Steve, <br />My client asked that 1 bring the follotcin¢ certain tnaners to your attention concerning recent actions by <br />San Migue]•Counry cottcemittg operations at Pathfinder. <br />I am in receipt of your August 16, 2000 lever to the DMG. In your letter, you indicate that the <br />County is in support of certain proposed actions by the DMG which, as you are no doubt aH•are, <br />would cause significant interruptions upon ]awful operations in the Pathfinder pit by my client <br />end w-i11 result in the loss of substantial econontie re.•enues. Your letter recites several passages <br />for which I seek the fo1lo~~n¢ insight er information: <br />A. You indicate that the penstock has repeatedly failed over a period of decades, please <br />provide any and all supporting information relied upon by the County in support of this <br />contention and please confirm that the poniott of the penstock having expenenced these <br />"failures" are located upon my client's property. <br />B. You indicate that "certain activities associated with the Pathfinder pit access road may <br />have exacerbated the penstock's condition and contributed to at ]east one, if not more, <br />significant pipeline failures." Please provide any and all supporting information relied <br />upon by the Counry in suppotZ of this contention. <br />C. You indicate that "within the past twe]t'e months, Public Service Company <br />representatives have advised the Board that the segment of the Ames penstock located in <br />proximity to the Pathfinder Pit access road has experienced movement due, in large part, <br />to unstable soils under and around the pipeline where it u•as constructed in one of the <br />filled drainages." The letter continues by discussing limitations concerning the pipeline <br />and how the pipeline is being stressed by truck traffe from Pathfinder. Please provide <br />any and all supporting information relied upon by the County in support of this <br />contention. <br />D. You indicate that Public Service Company has advised Pathfinder not to use certain <br />porrions of its haul road and rhat Pathfinder is continuing to use the road. Please protide <br />any and all supposing information relied upon by the Counry in support of this <br />contention. <br />G:\Clients\pathfinder.4059\06 t.ltr.wpd <br />