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~~~ <br />Y <br />III IIIIIIIIIIIII III <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1313 Sherman St.. Room 275 <br />Denver, CO 80203 <br />303 866-3561 <br />Fn x: 303 832-Bt06 <br />MEMO <br />OF'~~[p <br />N~ %> <br />•« <br />~ 18T6 <br />Ray Ramer, <br />Governor <br />Fred R. Banta. <br />Division Director <br />July 9, 1991 <br />To: Frank Johnson, Dave Berry, Larry Routten <br />From: Steve Renner <br />Ae: Anticipated legal Issues, FY91/92 <br />The legal issues which the coal staff anticipates will require attorney general <br />input during FY 91/92 are summarized below in order of decreasing priority. We <br />are currently allocated 780 hours of Attorney General time. I think that this <br />is a marginal allotment. Therefore, time needs to be budgeted carefully. <br />Please see my Memo of June 13, 1991 for the AG referral procedures. <br />~) Carbon Junction- Continue to monitor bankruptcy hearings in Texas; continue <br />to pursue terms of June, 1991 joint motion. <br />2j La Plata- Need to resolve conveyor status. Need to have bank install <br />sediment control system. Possible bond revocation. <br />3) Mid-Continent- Need to pursue permit revocation and bond forfeiture at the <br />January, 1992 Board meeting if terms of the settlement agreement are not met. <br />Meet in mid November to discuss. <br />4) Southfield/GEC- Need to draft a settlement agreement between Southfield, GEC <br />and the Division as soon as the Southfield tr technical issues are resolved. <br />Anticipate a late August completion. <br />5) Fruits- No permit at this site, but we hold a bond. We will probably <br />forfeit the bond at the Sept. or Oct. Board meeting. Possible settlement, but <br />highly unlikely. <br />t <br />6) Rulemaking- Anticipate the need to review proposed 181 rules and other rules <br />proposed as a result of 1989 733 letter from OSH. <br />7) Trinidad Basin- Revocation hearing was continued until the July Board <br />meeting. Anticipate minimal involvement. <br />STATE OF COLORADO <br />8) Blue Flame- Possibly a request for judicial review. If not, then probably <br />no involvement. <br />