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FROM :RGO NRT. RES. SECTION TO 1 303 2410336 199S,02-01 08:14 #OS4 F.02/03 <br /> .0 <br /> O <br /> ie �t <br /> STAT <br /> ING <br /> GALE A. NORTONi STAVE Off` COLORADO IVS S>rm—St $im15th <br /> Attorney General 15z5 Sherman Street-Sth Floor <br /> DEPARTMENT OF LAW Denver Colorado 802,03 <br /> STD K- cic Phone(303) 8664500 <br /> Chief Deputy Attorney General OmcE or THE A.rICuwkwY GzNERA1. FAX (30 ) 866-5691 <br /> T, OTHY M. TYMKOVIICH <br /> Solicitor General <br /> January 31, 1995 <br /> Joel W. Cantrick <br /> Pendleton & sabian, P.G. <br /> 303 East 17th Aveaue <br /> Suite 1.000 <br /> Denver, Colorado 80203-1263 <br /> RE: Division of Minerals and Geology v. Reeves et al. <br /> Dear Joel: <br /> We have received letters from Robert Delaney as Executive <br /> vice-President and General Counsel of Mid-Continent Resources and <br /> from Louis LaGiglia, the creditor's trustee in Resources' <br /> bankruptcy case, concerning a schedule for reclamation of <br /> Resources' mine site. As you are aware, the Division has put <br /> together such a schedule and we gave it to you on January 20 . <br /> Resources believes that its liquidation plan requires that <br /> the Division and Resources negotiate a reclamation schedule in <br /> the bankruptcy case. Although we do not agree with Resources' <br /> assessment in this respect, the Division concurs that such a <br /> schedule is beneficial in a number of ways. It facilitates the <br /> performance of reclamation; it informs the bankruptcy court, <br /> Resources and the defendants about the Division' s plan for <br /> reclamation; it informs the public about the reclamation plan; <br /> and it assists in discussions Concerning a potential land <br /> exchange with the U-S. Forest Service. indeed, prior to the <br /> confirmation of the liquidation plan, the Division, Resources, <br /> and the Office of surface Mining discussed a reclamation <br /> schedule, but to no avail . <br /> By statute, the Division has the authority and <br /> responsibility to ensure that. Resources' Irvine site is reclaimed <br /> to all applicable standards. To meet this responsibility, the <br /> Division has established the reclamation schedule we sent to you. <br /> The schedule not only sets forth the tasks necessary to complete <br /> reclamation to applicable standards, but also provides the <br /> estimated costs of each task, the date on which the Division <br /> needs funds for each task, and the projected completion date for <br /> each task. <br />