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FROM:natural TO-* 1 303 2410336 MAR 209 1995 1:22PM #942 P.02 <br /> DISTRICT COURT, PITKIN COUNTY, COLORADO <br /> Case No. 93CV201 <br /> AFFIDAVIT OF STEVEN RENNER <br /> DIVISION OF MINERALS AND GEOLOGY, DEPARTMENT OF NATURAL <br /> RESOURCES, STATE OF COLORADO, <br /> Plaintiff, <br /> V. <br /> JOHN A. REEVES; ROBERT DELANEY; DIANE DELANEY; AND MID-CONTINENT <br /> MINERALS CORPORATION <br /> Defendants. <br /> I, Steven Renner, do swear and depose as follows: <br /> 1. 1 am an Environmental Protection Specialist with the <br /> Colorado Division of Minerals and Geology ("Division") and am <br /> presently the lead specialist assigned to the Mid-Continent <br /> Resources, Inc. ( "Resources") Coal Basin mine site ("mine site") . <br /> 2 . 1 have knowledge of the mine site, and I know that <br /> maintenance and reclamation must be performed at the site. <br /> 3 . In 1991, the Division estimated that the cost of <br /> reclamation would be approximately $2, 993, 000 . The current <br /> Division estimate of the cost which the State of Colorado would <br /> incur to reclaim the mine site is substantially in excess of <br /> $3, 000, 000 . <br /> 4 . The Division had not recalculated the estimated cost of <br /> reclamation at the mine site for a number of years. Reclamation <br /> cost estimates are generally evaluated every two and one-half (2 <br /> 1/2) years. The costs for the Mid-Continent mine site were <br /> calculated in 1991 and are again being calculated in 1994-1995 . <br /> 5 . There are a number of factors which contributed to the <br /> Division not recalculating the estimated costs prior to this <br /> time: <br /> (a) Mid-Continent Resources was negotiating the sale <br /> of the mine site until July, 1992 . A new operator may not have <br />