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GENERAL43778
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Last modified
8/24/2016 8:12:35 PM
Creation date
11/23/2007 12:38:14 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977376
IBM Index Class Name
General Documents
Doc Date
5/3/1993
Doc Name
REPLY TO DEBTORS OBJECTION TO MLRB MOTION DATED 4/2/93 FOR PAYMENT OF ADMINISTRATIVE EXPENSE
Media Type
D
Archive
No
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The Mined Land Reclamation Board ("Board") replies to the reor- <br />ganized CFSI Debtors' ("Debtors") objection to the Board's motion <br />for an administrative expense as follows: <br />In its motion the Board requests an administrative priority <br />for two of the Hoard's claims against the Debtors: (1) an an- <br />nual permit fee in the amount of $490, and (2) the cost of <br />reclaiming the Monarch Quarries. <br />THE ANNUAL FEE <br />The Board's motion seeks payment of $490.00 for the 1993 <br />annual fees for reclamation permit number M-77-377. The fee is <br />specified by X34-32-127(2)(a)(III)(D), C.R.S. (1992 Supp.) Debt- <br />ors' sole objection to the payment of this fee is their claim <br />that they will have no obligation to pay the annual fee if the <br />Court grants Debtors' motion to abandon the quarries. Bowever, <br />an order granting the motion to abandon the quarries should have <br />not effect on the Board's claim for payment of the annual fee. <br />The Board has already incurred the burden and expense of adminis- <br />tering this permit postpetition. The annual fees are are <br />intended to defray the direct and indirect costs incurred in the <br />administration of the agencies charged with ensuring that mine <br />sites are reclaimed. Sections 34-32-122(1)(a) and <br />34-32-127(1)(b), C.R.S. (1992 Supp.) The maintenance of the <br />permit is a cost of preserving the estate against civil penalties <br />for operating without a permit. Section 34-32-123, C.R.S. (1984 <br />-2- <br />
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