_GENERAL DOCUMENTS - C1981017 ‎(245)‎

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Name: Bid Documents ‎(IMP)‎ TR-17 Correspondence
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

MINED LAND RECLAMATION DIVISION
Department of Natural Resources
1313 Sherman St., Room 215
Denver, CO 80203
303 866 -3567
FAX• 303 832 -8106
December 10, 1990
Mr. Greg McKennis
Garfield Citizens Alliance
Box 111
Silt, CO 81652
STATE OF COLORADO
Re: Coal Basin Mine, Technical Revision No. 17, File No. C -81 -017
Dear Mr. McKennis:
This letter is in response to your request for an informal conference
regarding Mid Continent's proposed water treatment plan.
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Roy Romer,
Govemor
Fred R. Banta.
Division Director
As we have previously discussed, the regulatory time frames associated with a
technical revision conflict with the time frames asset out in Rule 2.07.3(6)
pertaining to an informal conference. For Technical Revision No. 17, the
deadline for our proposed decision is December 21, 1990. It would not be
possible to schedule an informal conference and provide for the notice and
comment periods specified in Rule 2.07.3(6), and still meet the December 21,
1990 deadline.
We recognize that there needs to be a review of the informal conference and
technical revision process. To that end, we have requested a review by the
Assistant Attorney General. We will obtain a legal opinion and may pursue a
declaratory order from the Colorado Mined Land Reclamation Board or rule
making, if necessary, to resolve this matter.
We want to provide you with an opportunity to provide your comments and
concerns regarding the technical revision application. If you wish, we will
schedule such a meeting during the week of December 17, 1990. Representatives
of Mid - Continent Resources will be present to discuss their proposed mine
water treatment plan as addressed in Technical Revision No. 17.
Representatives of the Crystal Valley Environmental Protection Association
have expressed an interest in this issue. and they will also be invited to
attend the meeting. Due to the regulatory decision deadline and the
importance of implementing the plan as soon as possible to prevent future
non - compliance discharges, it is my belief that the public notice requirements
and time frames of Rule 2.07.3(6), and the 20 day comment period of
Rule 2.07,4(2)(a) should not apply because they may prevent accomplishing
remedial action necessary to protect the environment.