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INTRODUCTORY REMARKS <br />ARCO Coal Company, a division of Atlantic Richfield Company, <br />in response to the Public Notice that was published in the <br />North Fork Times on November 19, 1981, hereby submits <br />comments on the Technical Revision to the Revised Colorado <br />Mined Land Reclamation Permit Application dated November 6, <br />1981, submitted by Bear Coal Company. Atlantic Richfield <br />Company (ARCO) owns some surface and mineral acreage in <br />the permit request area and has significant surface and <br />coal leasehold interests in the surrounding lands. We <br />have a pending D7ine Permit Application for lands East of <br />Bear's permit request area. We appreciate the opportunity <br />to make these comments. <br />C O M M E N T S <br />1. ARCO is the surface owner of NE}NEB and SANE} in Section <br />17, T13S, R90W. ARCO is also the surface owner of lands <br />in Section 8 adjacent to Tract A of Bear Coal Company's <br />permit request area. The Applicant, in his description <br />of three rights-of-way, as well as what is indicated on <br />various maps, appears to claim surface rights on lands <br />that are owned by ARCO. ARCO has not granted any right- <br />of-way to the Applicant nor has ARCO entered into any <br />agreement which would allow the Applicant to construct <br />and operate a conveyor or surface facility or to use any <br />of ARCO's lands for any purpose whatsoever. <br />2. The description of Tract "A" as published in the North <br />Fork Times does not close. We wish to reserve the oppor- <br />tunity to comment further when a legally sufficient <br />description is provided. <br />3. The description of right-of-way (3) does not correspond <br />with the map that purportedly depicts the right-of-way. <br />we wish to reserve the opportunity to comment further <br />when this discrepancy is cleared up. <br />4. We are not able to ascertain from the information contained <br />within the application how the coal produced from the <br />mine will be transported. We wish to reserve the oppor- <br />tunity to comment further when the transportation is <br />more fully explained so that we can better determine the <br />effect on our own transportation plans. <br />