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6 C)G? C)-7 nAQAr <br />Venture Resources, Inc. <br />PO Box X974 (303) 619-6323 <br />Idaho Springs, CO 80452 Fax: (303) 484-6369 <br />venttireresources Csatt.uet <br />July 22, 2009 <br />CO Division of Reclamation, Mining & Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 jU 2 4 2^009 <br />Attn: CO Mined Land Reclamation Board ?y <br />Mining and Safety <br />RE: Petition for Declaratory Order <br />Subject: Abandoned Mine Waste Rock - Voluntary Reclamation <br />Dear Members of the Board: <br />II <br />Venture Resources wishes to petition the Board for clarification on the whether the activity of voluntary <br />reclamation, through removal and off-site processing of abandoned mine waste rock falls under the definition of <br />"Mining Operation", as it is described in Mineral Rules and Regulations for Hard Rock, Metal, and Designated <br />Mining Operations. Specifically, Rule 1- Definitions states: <br />(31) "Mining Operation" means the development or extraction of a mineral from its natural occurrences on <br />affected land. The term includes, but is not limited to, open mining and surface operation and the disposal <br />of refuse from underground and in situ mining. The term includes the following operations on affected <br />lands: Transportation-, concentrating; milling; evaporation-, and other processing. The term does not <br />include: The exploration and extraction of natural petroleum in a liquid or gaseous state by means of wells <br />or pipe; the development or extraction of coal; the extraction of geothermal resources; smelting, refining, <br />cleaning, preparation, transportation, and other off-site operations not conducted on affected land. <br />It is our position that this activity does not constitute a "Mining Operation" and therefore does not require a mining <br />permit. Following, we will provide our reasoning in this Petition. <br />To provide some background, Venture Resources' sister real estate company, Red Tail XP, has purchased over 60 <br />patented mining claims scattered about in the Russell Gulch and Virginia Canyon region of Gilpin and Clear Creek <br />counties. These properties were acquired as a real estate investment in anticipation of the newly constructed Central <br />City Parkway bringing increased development interest to the region. <br />Needless to say, current economic conditions have significantly softened the real estate market. We began to re- <br />examine our property holdings to see what options we had. On many of our parcels exist abandoned mine waste <br />rock dumps that were deposited throughout the period of unregulated gold mining during the late 19`' century. We <br />recognized that to make a more attr4ctive real estate presentation,. these dumps will have to be reclaimed. They are <br />not only an eyesore, but pose serious environmental damage due to acidic mine water run-off. <br /> <br />Page 1 of 5 <br />