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PARCEL, MAURO, HULTIN & SPAANSTRA, P. C. <br /> ATTORNEYS AT LAW <br /> SUITE 3600 <br /> 1801 CALIFORNIA STREET <br /> DENVER,COLORADO 80202-2636 <br /> TELEPHONE(303)292-6400 <br /> TELECOPIER(303)295-3040 <br /> January 17, 1994 gpnj:�-<<'rz. . <br /> BY HAND DELIVERY BAN I Y <br /> Mr. Larry P. Routten <br /> Environmental Protection Specialist <br /> Colorado Division of Minerals <br /> and Geology <br /> 1313 Sherman Street, Room 215 <br /> Denver, Colorado 80203 <br /> Re: Formal Hearing Request on Cessation Orders C-93-140, C-93-144, C-93-145, <br /> and C-93-148 Issued by the Colorado Division of Mineral and Geology to <br /> Mid-Continent Resources, Inc. <br /> Dear Larry: <br /> On January 7, 1994,we requested on behalf of Mid-Continent Resources, Inc., formal <br /> hearings before the Mined Land Reclamation Board ("Board") on the above referenced <br /> cessation orders ("COs"). As you may be aware, the 90 day period within which a request <br /> formal hearing on CO C-93-140 could be made was to expire on January 10, 1994. In <br /> addition, on December 8, 1993, the Division issued a Notice of Proposed Civil Penalty and <br /> Request for Conference for COs C-93-140, C-93-144, C-93-145. We understand that Mid- <br /> Continent completed the Request for Conference portion of each Notice and returned them <br /> to the Division. Assessment Conferences have not yet been scheduled for these COs. Mid- <br /> Continent has not received a Notice of Proposed Civil Penalty and Request for Conference <br /> on CO C-93-148. <br /> In our telephone conversation last week, you indicated that the applicable rules are <br /> somewhat ambiguous and could require a hearing in January. As you know, Mid-Continent <br /> believes that the appropriate timing for such hearings would be the February or March <br /> Board meetings. We would note that the Board's Rules provide for the consolidation of <br /> formal hearings before the Board where appropriate to ensure efficient use of the Board's <br /> resources. Specifically, Rule 5.04.4(2) states that, "When appropriate the Board shall <br /> consolidate . . . [public hearings on penalties] with other proceedings under . . . 5.03.5." In <br /> this regard, we would note that COs C-93-144, C-93-145, and C-93-148 are derivative of <br /> NOVs which are still under deliberation by an assessment conference officer and the <br />