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~iiiiiiiiiiiiiiuiii <br />999 <br />PARK AVENUE TOWER <br />65 EAST 55TH STREET <br />NEW YORK, NEW YORK 100 2 2-3 2 1 9 <br />Izlzl 7so-soso <br />DAVID 5. NESLIN <br />DIRECT LINE: 13031 863-2301 <br />U BLE: '•p8iO P0'• <br />TELECOPI ER: 13031 832-0428 <br />May 6, 1992 <br />1200 NEW HAMPSHIRE AVENUE. N. W. <br />WASHINGTON, D. C. 20036 <br />120218]2-6700 <br /> <br />Ms. Catherine W. Begej JIAY 13 1991 <br />Reclamation specialist AAined Land <br />Mined Land Reclamation Division Reclamation D~"~~~~~ <br />Colorado Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: April 25 Petition by Dr. W.D. Corley <br />Dear Ms. Begej: <br />On behalf of our client, Harrison Western <br />Corporation, we are responding to Dr. W.D. Coney's <br />latest petition, dated April 25, which accuses Harrison <br />Western of violating two surface coal mining regulations <br />and asks the Board to levy "appropriate penalties." <br />First, the petition erroneously states that at <br />the Board's last meeting, I "testified that Harrison <br />Western did drill" an exploratory hole at the GEC <br />Minerals site. In fact, I merely stated, as I have in <br />the past, that neither I nor Harrison Western's current <br />management know who drilled the hole but that, assumincx <br />it was drilled by Harrison Western, this would indicate <br />that Harrison Sestern's bond was intended to cover only <br />the area depicted in exhibit A to the bond, and that the <br />drill hole did not materially expand the disturbed area. <br />Second, the regulatory violations alleged by <br />Dr. Corley are spurious. Assuming, solely for the sake <br />of argument, that Harrison Western drilled the hole in <br />question, it presumably did so to determine its ability <br />to access the then existing Newlin Creek Mine from the <br />West Pit, which would not constitute "coal exploration" <br />under the regulations. See Rule 1.04(22). Nor did the <br />work in question "substantially disturb[] the natural <br />land surface," as is required to trigger Rule 4.21. See <br />Rules 4.21.1 & .2. As the work in question, if <br />A$NOLD 8c POATEl3 <br />ONE UNITED BANK CENTER <br />1700 LINCOLN STREET <br />DENVER, COLORADO 60203 <br />(3031 863-1000 <br />