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~~E , ~'paQJ,',e(/,( v- 3 III IIIIIIIIIIIII III Doc Date:,2/11/2001 ROBERT F. WELBORN •JOiEPIr E LOOM THOMAS G BROwN IOM LEAV [I DAVID W. FU RG ASON Hlt ES C. CO RT EZ. JR. wIL L1AM C. ROBE JOHN F. WELBORN WILLIAM A M[LAIN BEVERLY J.OUAIL JOHN D. FAUGHT RIC HAPD L. FANYO G OROON w. NETZORG DEBRA R. LAP PIN M IC MAEL M. PAGE WELBORN, DUFFORD, COOK 8 BROWN ATTORNEYS AT LAW 1100 UNITED BANn OENTER DENVER.COLORADO 80290 TELEPHONE (]O ]( Bel-BOI] OF COUNSEL PHILIP G. DUFFORD October 2, 1979 Antonio R. Durando, Esq. Northwest Energy Company 315 East 200 South Salt Lake City, Utah 84111 Re: BLM Coal Lease No. C-27103 Dear Tony: EXPRESS MAIL Enclosed for your review is a copy of the Lease which BLM intends to have Western Slope Carbon execute on October 9. It is essentially the same as the form contained in the' materials announcing the lease offering which you received • sometime ago. I understand however that there may have been some alterations in Section 23 regarding readjustment. I am reviewing the lease and understand that Peter would like you to do likewise. I am particularly checking the lease in comparison with the new Federal Coal Leasing Regulations which became effective on July 19, 1979. BLM has been somewhat uncertain regarding how to handle leases such as this one which were begun before those regulations became effective but are not to be completed until afterward. They would accept a lease ir. the enclosed form or the enclosed form amended to fully comply with the new regulations, for which a new lease form has not been developed as yet. My only concern is the risk that a third party might challenge the validity of the lease issued some three months after the effective date of the new regulations if it did not comply therewith. Therefore I am reviewing the new lease in comparison with the final regulations to identify the differences and to evaluate the risk of a third party challenge. o ~c~g~~~ p OCT 41979 WESTERN SLOPE CAR80N, INC.