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AUG 23 193 16:28 TO: 303 832 8106 P03 <br /> Mr. Steven G. Renner <br /> August 23, 1993 <br /> Page - 2 <br /> A considerable part of the $300,000 allocation and of the <br /> work performed has been directed to maintenance and abatement <br /> matters and other matters outside reclamation plan requirements <br /> required by your Division this summer that retard the reclamation <br /> program. <br /> It was anticipated that a substantial cash flow would be <br /> developed from sale of machinery and equipment. However, this has <br /> not happened. These sales are disappointing. We have no assurance <br /> from Machinery & Equipment Company that sales will accelerate to <br /> any substantial degree in the near future. <br /> The obvious source of funds to provide reclamation under <br /> the difficult circumstances in this case must be the sale proceeds <br /> of the reclaimed property, plus sale proceeds of the Rock Dust <br /> Plant. If this reclamation can proceed in a manner that will allow <br /> post mining uses in accordance with prior planning, then the sale <br /> proceeds should be adequate for the purpose. <br /> The only immediate solution as I see it, will be to try <br /> to arrange an additional interim financing program whereby a <br /> priority loan can be worked out against ultimate sales proceeds of <br /> the reclaimed property. <br /> Without some material changes in the reclamation program <br /> currently in practice, I do -not believe this will be possible. <br /> One of the largest impediments is the seemingly <br /> inconsistent position of MLRD. Please refer to my letter to Mr. <br /> Frank Johnson dated August 3, 1993, copy attached. <br /> On July 23, 1993 you issued Notice of Violation for <br /> "failure to contemporaneously reclaim the Coal Basin mine site" <br /> (presumably according to the May 22, 1991 Board Order. ) Everyone <br /> familiar with the situation knows this is impossible. MCR <br /> requested revision of the reclamation schedule and was advised that <br /> the regulations do not allow the Board to establish a "compliance <br /> schedule" with a bankrupt company. 1 <br /> 1 3.04 CCR - FORFEITURE OF PERFORMANCE BONDS <br /> (1) The Hoard shall declare all or any appropriate part <br /> of a performance bond for any permit as forfeited if the Board <br /> determines that any of the following circumstances exist: <br /> (c) The permit has been suspended or revoked, and <br /> neither the permittee nor the surety has assumed <br />