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III IIIIIIIIIIIIIIII <br />999 <br />PARCEL, MAURO, HULTIN & SPAANSTRA, P.G. <br />ATTORNEYS AT LP.W <br />' SUITE J600 <br />IB OI CALIFORNIA STREET <br />DENVER. COLD RADO 80202 <br />TELEPHONEIJO]12926400 <br />B RENT C. ANDERSON <br />TELECOPIER I]O]1295JOa0 <br />~~~~~~ ~® <br />DELIVERED BY ME88ENGER <br />May 6, 1991 <br />Mr. Steve Renner <br />Colorado Mined Land Reclamation Division <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: The Rockcastle Company, Grassy Gap <br />C-81-039) -- Comments on Office of <br />Reclamation and Enforcement ("OSM") <br />("TDN") No. 91-2-116-4 TV3. <br />Dear Steve: <br />M py 61991 <br />Mined Land <br />Reclamation Division <br />Mine (Permit No. <br />Surface Mining, <br />Ten-Day Notice <br />The following comments are submitted on behalf of the <br />Rockcastle Company ("Rockcastle") in response to OSM's April 10, <br />1991 decision regarding the Colorado Mined Land Reclamation <br />Division's ("CMLRD") April 2, 1991 response to TDN 91-2-116-4 TV3. <br />The TDN raises numerous issues regarding the June 26, 1990 <br />Agreement between CMLRD an3 Rockcastle (the "Agreement"), and the <br />bond release process contained therein. OSM's concerns are related <br />to an apparent misconception of the circumstances surrounding <br />execution of the Agreement, and a misunderstanding of the terms and <br />objectives of the Agreement. The Agreement was entered into to <br />abate NOV C-90-007 and NOV C-89-034, and to provide the framework <br />for a compliance schedule in lieu of bond forfeiture pursuant to <br />CMLRD Rule 3.04.1(2). The Agreement sets forth the specific <br />reclamation activities to be completed at the site. More <br />importantly, through the Agreement, CMLRD and Rockcastle have <br />avoided costly and unnecessary litigation, and Rockcastle has <br />accomplished on the ground reclamation in accordance with the CMLRD <br />rules. <br />Rockcastle is particularly concerned that OSM is challenging <br />CMLRD's bonding practices and its ability to enter into settlement <br />