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<br />In their Motion for Adequate Protection and Relief From <br />Stay, the Lenders seek to force the taxpayers of Colorado to <br />pay for reclamation in Colorado which will preserve the value <br />of the Lenders' collateral in Ohio, by forestalling a chain of <br />events which would block the Debtor Harrison Mining from <br />revising or amending its Ohio permits on the profitable Ohio <br />mines that are a major element of the Lenders' collateral <br />package. This Court should not allow such a result. <br />"[Section] 506(c) is grounded in the equitable principle that <br />a secured creditor should not enjoy a windfall at the expense <br />of the claimant." In re Guterl Special Steel Corp., 198 B.R. <br />128, 136 (Bankr.W.D.Pa.1996) (citing In re Visual Industries <br />Inc., 57 F.3d 321, 324-25 (3d Cir. 1995). <br />POINT IV <br />The Lenders Are Proposing a De Facto Abandonment of the <br />Powderhorn Site, And They Have Not Met the Standards for <br />Abandoning a Contaminated Site <br />The practical effect of allowing the Lenders to receive <br />the proceeds of the sale of the Machinery and Equipment is to <br />strip the Powderhorn estate of most of its salable, valuable <br />assets. All that will remain in the Powderhorn estate is the <br />unreclaimed real property, which presents significant and <br />immediate hazards to public health and safety. Although there <br />26 <br />