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<br /> <br />DIVISION OE MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1 311 Sherman 51.. Room ? I S <br />Derner, Cfl X11201 <br />Phone: 130}1 A6fi-7507 <br />FAC:I10318:f 2-8106 <br />DATE: Apti121, 1993 <br />TO: Steve Renner <br />Michael bong <br />;=icGivl: David Betry~~~ <br /> <br />STATE OF COLORADO <br />of cow <br />.,`e_ 4 <br />~. ~ <br />r. <br />',p <br />Rov Romer <br />Wvernor <br />.~sichael B LOUR <br />Divivon D~reaor <br />RE: Notice of Violation No. C-93-006 <br />Mountain Coal Comoanv. Permit No. C-80-(X17 <br />;' ~~ memcrandum is written in response to the April 16, 1993 correspondence received from <br />~.".'. Andersen of Mountain Coal Company. <br />I strongly recommend that the above-referenced violation not be vacated. The violation was <br />written for failure to submit three subsidence reports to the Division office, and there is <br />absolutely no evidence that any reports were submitted during 1991 and 1992. The <br />arguments presented by Mountain Coal Company seem to be an attempt to obscure a simple <br />issue. <br />Mountain Coal claims that the three reports (June 1991, October 1991, and June 1992) were <br />ai~~en to our inspectors in the field, then subsequently lost by our ~:ar.". We ::ave ~xured all <br />of the Division files, including the specialist's files, the public files, arld Dr. Pendleton's files <br />and we cannot 1md any reports. Mountain Coal Company cannot produce any report or <br />cover letter copies. <br />Tne affidavit provided by Mountain Coal Company must be reviewed and considered with <br />caution. Note that statement number 5 in the affidavit states "...I occasionally provided <br />copies of the subsidence monitoring reports to inspectors from the Colorado Mined Land <br />Reclamation Division...". This may be true, but this statement does not verify, in any way, <br />that the reports for 1991 and 1992 were submitted for formal filing with the Division. The <br />affidavit merely verif-ies that some reports were provided at some unknown time, for perusal <br />by our staff (individuals unknown), probably in conjunction with our normal records checks <br />during complete inspections. It is highly unlikely that three different reports were lost by <br />our staff. <br />