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November 15, 1991 <br />Director <br />Colorado Mined Land Reclamation Division <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />Director <br />Office of Surface Mining <br />625 Silver Avenue SW <br />Suite 310 <br />Albuquerque, New Mexico 87102 <br />RE: <br />COMPLAINT: <br />Mid - Continent Resources <br />Permit Violation <br />File #C- 81 -01F <br />R ECEIVED <br />NOV 181991 <br />Recta l ned Land <br />atl0n DN►S10, <br />Contrary to requirements of law, the reclamation bond <br />put up by Mid - Continent Resources is grossly inadequate to cover <br />the costs of reclamation. <br />According to the MLRD Midterm Review finalized in April <br />1991, the Division holds a reclamation bond for the Coal Basin <br />mines in the amount of $3,000,000 in the form of a Deed -of -Trust <br />to real property. The real estate appraisal of the property <br />which the Division relies upon is dated May 19, 1988. According <br />to that appraisal (done by Applegate & Company), the value of <br />the property at that time was $3,340,000. Adjusting that figure <br />for 3 -1/2 years of depreciation (from 5 -19 -88 to 11- 19 -91), <br />however, the estimated current value is only about $2,376,000 <br />far short (over $600,000 short) of the $2,993,000 cost of <br />reclamation estimated by the Division. The shortfall will be <br />significantly greater if unpaid back taxes are considered. <br />I hereby request that the Division take immediate <br />action to require Mid - Continent Resources to post additional <br />bonds forthwith. <br />I further <br />Division to assure <br />possible. This is <br />ask that OSM issue a Ten Day Notice to the <br />enforcement action is taken as soon as <br />in consideration of the fact that the <br />