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not list The Victor-American Fuel Company as the owner of coal <br />in Section 15. Such an omission was a violation of C.R.S. <br />§34-33-110 (2S (g) (1983 Supp.). As a result of Trinidad Basin <br />Mining, Int.'s failure to notify The Victor-American Fuel Company <br />of the pending application or to list it as the owner of Section <br />15 coal in the published notice, The Victor-American Fuel Company <br />was deprived of its right to petition for and zeceive an informal <br />conference opposing Trinidad Basin Mining, Int.'s permit appli- <br />cation in accordance with C.R.S. §34-33-118(4) and (6) (1983 Supp.), <br />and, if necessary, to petition for and receive a formal hearing <br />opposing the issuance of the permit in accordance with C.R.S. <br />§34-33-119(4) - (B) (1983 Supp.), and, if necessary, to obtain <br />judicial review pursuant to C.R.S. §34-33-128 (1983 Supp.). <br />REQUESTED RELIEF: <br />The Victor-American Fuel Company requests the Colorado Mined <br />Land Reclamation Board to issue a declaratory order pursuant to <br />C.R.S. §24-4-105 (1973) and Rule 1.14, 2 C.C.R, 407-2 holding <br />that Permit No. C-048-81 is invalid insofar as it covers the coal <br />in Section 15 which is owned by The Victor-American Fuel Company. <br />Respectfully submitted, <br />HOLLAND & HART <br />By: <br />555 Seventeenth Street, #2900 <br />P. O. Box 8749 <br />Denver, Colorado 80201 <br />Telephone: (303) 295-8000 <br />ATTORNEY FOR PETITIONER <br />THE VICTOR-AMERICAN FUEL COMPANY <br />- 3 - <br />Joy E. Hansen <br />