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' Mr. Car] Mount <br />June 23, 2000 <br />Pave 2 <br />One of the declared intentions behind the Mined Land Reclamation Act for the Extraction <br />of Construction Materials was to provide for an "economically sound and stable extraction materials <br />industry and to encourage the orderly development of the state's natural resources while requiring <br />those persons involved in the extraction operations to reclaim land affected so that it may be put to <br />beneficial use to the people of this state." C.R.S. § 34-32.x-102(1) 1999. If the resources in Stage <br />1 are not yet exhausted (and [he Mining Table would appear to suggest that they will not be <br />exhausted for decades), permitting operations to spread to another area in Stage 2 needlessly would <br />not be consonant with that expressed intent. In fact, allowing Stage 2 mining to begin while <br />resources yet remained at [he Stage 1 mine is wasteful, unnecessary, and does not represent an <br />"orderly development of the state's natural resources." Robco has made no showing of why such <br />a revision is necessary or desirable when, in fact, it is neither desirable or necessary. <br />As mentioned in previous correspondence with your office, our firm represents John W. <br />Stockwell, Ir., the surface owner of the above-listed property. While Mr. Stockwell understands the <br />Division of Minerals and Geology's policy is to encourage mining in the State of Colorado, Mr. <br />Stockwell strongly opposes any Technical Revisions to the Lariat Mine Permit for several reasons. <br />The proposed Technical Revision will allow concurrent mining within Stages 1 and 2 of the <br />O Lariat Mine. This is a major change. The 1987 permit stated mining in Stage 2 will not begin until <br />all the surface mining in Stage 1 is complete. This substantial change severely impacts the surface <br />ownership rights of our client in the North r/z of Section 16, especially in view of the fact the Mining <br />Timetable on page 11 of the existing permit indicates that Stage 1 will be mined over a period of ~0 <br />to 80 years and Stage 2 will be mined from over a period of 40 to 80 years. Moving the mining of <br />Stage 2 up from almost 40 yeazs in the future to today is a maj or change. The existing permit, Permit <br />No. M-77-251 states that "Mining in Stage 2 will not begin until all surface mining in Stage 1 is <br />complete." See Exhibit D at page 9. The changed language proposed by Robinson will allow Stage <br />2 to begin immediately. The changes to pages 9 and 11 of Exhibit D would allow Stage 1 (the <br />Lockheed-Martin Mine) and Stage 2 (the North'/z of Section 16) to be mined concurrently. The <br />Mining Timetable states Stage 1 would take 50 to 80 years to be completed. Under the existing <br />permit, Stage 2 mining could not begin until that time, which means Stage 2 mining would not occur <br />for 40 to 70 years in the future from today. This amendment will allow Stage 2 mining to take place <br />on Mr. Stockvvell's property immediately, as faz as the Reclamation Board is concerned. This is a <br />substantial and material change reducing a delay of 40 to 70 years to "0" yeazs. <br />Second, Pazagraph 3 of your May 1, 2000 Colorado Division of Minerals and Geology <br />Minerals Program Inspection Report, states that the "... DMG will, however, reevaluate the amount <br />of bond required in the next 60 days to see if it is adequate to reclaim the amount of disturbance <br />allowed under present permitting scheme." Mr. Stockwel]'s position remains that the corporate <br />surety bond for the Lariat Mine is inadequate and needs to be increased. The bond for the Lariat <br />O Mine was established in 1957, over 13 years ago. The cost of reclamation has significantly increased <br />over time. The Denver Metropolitan area is a thriving economy and the value of ]and itself has risen <br />