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Comments on Findings <br />Legal, Financial and Compliance Information - Rule 2.03 <br />There has been a series of changes in the ownership and operators of the <br />mine. The original operator was Colorado Coal Mining Company, owned by Perma <br />Resources Corporation. The ownership was later transferred to the Kaiser <br />Steel Corporation. Subsequently, under the Plan of Reorganization as approved <br />by the Bankruptcy Court, the controlling company became Kaiser Steel <br />Resources, Inc., which is a company totally separate from the previous Kaiser <br />Steel Corporation. The compliance information required under this rule has <br />been updated by the applicant in their November 15, 1988 Renewal Application <br />and January 20, 1989 - Responses to Adequacy Comments. <br />Pursuant to Rule 2.07 .6(2)(f), the Division has determined that for this <br />operation, private mineral estate has been severed from private surface estate <br />on portions of Section 25 of the permit area, however, the surface owner is <br />the mining company. On May 2, 1988, the mineral rights to Section 36, a State <br />of Colorado property, were leased by the State to the Western States Minerals <br />Corporation. The surface rights have been leased to Mr. Joe Faris. Since it <br />appears that Kaiser Steel Resources no longer has surface or mineral control <br />of Section 36; and since there are water monitoring wells on this Section <br />which must be sealed, the following Stipulation is necessary. <br />Stipulation No. 21 <br />THE PERMITTEE MUST OBTAIN LEGAL RIGHT OF ACCESS TO SECTION 36 FOR THE <br />PURPOSE OF PERFORMING APPROVED RECLAMATION ACTIVITIES. SUCH RIGHT OF <br />ACCESS MUST BE OBTAINED PRIOR TO ENTERING THIS SECTION. THE RIGHT OF <br />ACCESS MUST BE OBTAINED WITHIN 30 DAYS OF THE PERMIT RENEWAL APPROVAL. <br />With the acceptance of this stipulation, the proposed operation is in <br />compliance with the requirements of this section. <br />II, Land Use - Rules 2.04.3, 2.05.5 and 4.16 <br />There are no changes to this section. <br />III. Cultural and Historic Resources - Rules 2.04.4 and 2.05.6(4) <br />There are no changes to this section. The original Findings Document stated <br />that no cultural and historic resources listed on the National Register of <br />Historic Places has been identified within the permit area. <br />No new surface disturbances are proposed in the prroposed permit renewal, <br />therefore, these findings are still valid. <br />Pursuant to Rule 2.07 .6 (2)(e), the Division finds that the mining operation <br />will not adversely affect any publicly owned park or place listed on the <br />National Register of Historic Places. <br />The application is in compliance with the requirements of this section. <br />-6- <br />