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<br /> <br />WELBORN, DUFFORD, BROWN Fd TOOLEY <br />Colorado Mined Land <br />Reclamation Division <br />May 6, 1986 <br />Page Four <br />Division's offices on April 25. (A meeting on April 24 could <br />not be arranged because of the Board meeting.) As a result of <br />Trapper's efforts, along with the Division's excellent <br />cooperation, the technical revision was proposed for approval <br />on April 25 and published on the next possible date, April 29, <br />1986. This was, indeed, the shortest possible time for <br />completing the abatement action and justifies full good-faith <br />credit of $1,250, or an amount at least sufficient to offset <br />any proposed assessment under the other categories. <br />For these reasons, Trapper submits that no civil <br />penalty should be assessed for the NOV. <br />Finally, Trapper submits that there is a basis for <br />vacating the NOV on the grounds that no violation occurred. <br />Trapper will reserve presentation of the details on this point <br />until any assessment conference. <br />We appreciate your consideration of these comments. <br />Sincerely yours, <br />WELBORN, DUFFORD, BROWN & TOOLEY <br />./ ~~ /^ <br />Richard L. Fanyo ' <br />Attorneys for TrappeC Mining Inc. <br />RLF;cae <br />cc: H. Bruce Humphries <br />