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<br /> <br />r <br />, <br />~ <br />\ <br />III III III'll llll III <br /> <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />7373 Sherman St., Room 275 <br />Denver, CO 60203 <br />303 666-3661 <br />Fax: 303 832-6706 <br />pF' p0~ <br />,~6 _ 4,~ <br />He O <br />`~ . <br />•~ <br />re'!e <br />July 9, 1991 <br />MEMO <br />To: Frank Johnson, Dave Herry, Larry Routten <br />From: Steve Renner /' <br />Re: Anticipated legal Issues, FY91/92 <br />Roy Romer, <br />Governor <br />Freo R. Banta. <br />Division Drtector <br />The legal issues which the coal staff anticipates will require attorney general <br />input during FY 91/92 are summarized below in order of decreasing priority. We <br />are currently allocated 780 hours of Attorney General time. I think that this <br />is a marginal allotment. Therefore, time needs to be budgeted carefully. <br />Please see my Memo of June 13, 1991 for the AG referral procedures. <br />1) Carbon Junction- Continue to monitor bankruptcy hearings in Texas; continue <br />to pursue terms of June, 1991 joint motion. <br />2) La Plata- Need to resolve conveyor status. Need to have bank install <br />sediment control system. Possible bond revocation. <br />3) Mid-Continent- Need to pursue permit revocation and bond forfeiture at the <br />January, 1992 Board meeting if terms of the settlement agreement are not met. <br />Meet in mid November to discuss. <br />4) Southfield/GEC- Need to draft a settlement agreement between Southfield, GEC <br />and the Division as soon as the Southfield tr technical issues are resolved. <br />Anticipate a late August completion. <br />5) Fruits- No permit at this site, but we hold a bond. We will probably <br />forfeit the bond at the Sept. or Oct. Board meeting. Possible settlement, but <br />highly unlikely. <br />6) Rulemaking- Anticipate the need to review proposed 181 rules and other rules <br />proposed as a result of 1989 733 letter from OSM. <br />7) Trinidad Basin- Revocation hearing was continued until the July Board <br />meeting. Anticipate minimal involvement. <br />~) Blue Flame- Possibly a request for judicial review. if not, then probably <br />no involvement. <br />STATE OF COLOR-ADO <br />