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~~ III IIIIIIIIIIIIIIII <br />999 <br />RECEIVED <br />/~ ~ ~ ; ` \, <br />~i, ~ ,>. ;- ~-:~ SEP 29 1997 <br />~. <br />i)ivisiCn or r,:ulcr,: ; ~. uL:CfC~, <br />ENERGY COMPANY <br />P.O. BO% 46] GOLDEN, COLORADO 80402 <br />September 26, 1997 <br />Mr. Byron Vlalker <br />Division of Minerals and Geology <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: "Proposed Decision & Findings of Compliance" <br />Permit Renewal No. 3 <br />Keenesburg Mine (Permit C-81-028) <br />Dear Mr. Walker: <br />Some time ago [indicated to you that Coors Energy Company (CEC) was in the process of <br />assembling comments in response to the Division's publication of the above referenced document, <br />in conjunction with the permit renewal process. These comments, while they should not necessarily <br />alter the renewal process (which we recognize is essentially concluded) are submitted "for the file", <br />and teat modification, if appropriate. CEC would ask that these responses be placed of rewrd to <br />acknowledge the differences of position with the Division, where they exist. <br />The comments which follow are organized to mirror the format of the Division's "findings" <br />document, with responses by section, paragraph and page number: <br />1. Introduction- paragraph 2- page 1. "The mine is located on state and private lands within <br />Weld County, ..." At the time the application was submitted to the Division for Permit Renewal <br />No. 3, all of the lands subject to the Permit had wme under private control. Section 36 (T3N, <br />R64W) was purchased by CEC from the State of Colorado under Paten[ No. 7988 dated October <br />28, 1993. <br />1.1 Legal Description- paragraph 5- page 2. °... Sheet 1 of 5 by Hall and Associated, Inc. as <br />pertains to the description was deleted." It is CEC's position that Sheet 1 of 5 (I-fall and <br />Associates) was not intended to be a part of the previous Permit description, either through MR <br />#22 or the Permit review and renewal process. The land description referred to on this Sheet is for <br />a portion of Weld Cowtty Road #59, which was upgraded through a realignment to tie into the <br />south end of the Mine Access Road. CEC acquired the lands described on this Sheet 1 of 5 in <br />order to facilitate the realignment process. It was not, as indicated in the "Findings Document" an, <br />