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rV~ III III III III IIII III <br />i <br />999 <br />STATE OF COLORADO <br />DIVISION OF INSURANCE <br />DEPARTMENT OF REGULATORY AGENCIES <br />First Western Plaza <br />303 West Collar Avenue, Suite 500 <br />Denver, Colorado 80204 <br />Phon e: (303) 620-4300 <br />February 28, 1989 <br />Susan J. Howry <br />Senior Reclamation Specialist <br />Hined Land Reclamation Division <br />215 Centennial Building <br />1313 Sherman Street <br />Denver, Colorado 80203-2273 <br />OF ~~/0 <br />~~ ~~ <br />Ne <br />o Roy Romer <br />Covemor <br />~p ~ Aeven V. Bosun <br />®® Executive Director <br />lohn Kezer <br />~~ G 1989 Com misvoner nl <br />Insurance <br />t~AR <br />EG~'MA ON D~ `~\p~ <br />Re: Self Insurance of Eastern Gas and Fuel Associates, Hlue Ribbon Mine, <br />Red Canyon Hine, No. Thompson Creek Hine <br />Dear Hs. Howry: <br />I regret I'm unable to give you a detailed response to the concerns <br />you raised in your February 7, 1989 letter. <br />Specifically, neither i nor my staff are aware of the Federal <br />self-insurance requirements for mining programs. I would encourage you to <br />check directly with whatever relevant authority exists in this area because we <br />have no familiarity with the program you administer. There is nothing in the <br />laws governing the Division of Insurance which addresses your issue and, <br />therefore, I must presume that the State requirements are those which were set <br />out in the attachment you provided me. <br />In response to your second concern, it appears that the Hined Land <br />Reclamation Division is the entity which must make the determination as to <br />whether the self-insurance is or is not satisfactory. In this context I <br />cannot give you any immediate guidance, but we are working on a similar issue <br />with respect to the role imposed upon us through Senate Bill 143 enacted last <br />year regarding self-insurance programs for medical malpractice insurance. If <br />our efforts to identify criteria by which self-insurance programs appear to <br />pass muster which are relevant to your program, I will forward a copy to you <br />as soon as we have completed our work -- which is in progress. <br />With respect to your last concern, the obligation in your <br />requirements for 5500,000 aggregate coverage appears to apply to each permit. <br />The Certificate provided for Eastern Gas and Gavle Associates does not break <br />the issue down by location, but appears to conglomerate all three entities in <br />