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LAW OFFICES OF <br />219 North Iowa Street Suite A Gunnison Colorado 81230 USA <br />LUKE J. DANIELSON, P.C. wwwldinielsonlaw.com p: (970) 641-4605 f (970) 641-4439 <br />Luke J. Danielson, luke@ldanielsonlawcom <br />Ms. Robin A. Reilley, GISP <br />Environmental Protection Specialist 0D <br />Division of Reclamation, Mining and Safety RF -Ce%* <br />Colorado Department of Natural Resources 5 Z01b <br />1313 Sherman St. 3W Q <br />Room 215 S,ON OF RECLARATION <br />Denver, CO 80203 DMMiNiNG ANO SAFETY <br />By United States Mail and by email to robin.reilley@state. co. us <br />RE: Supplemental Comments Regarding GCC Energy, LLC, King Coal Mine, Permit No. <br />C-1981-035, TRs 20 23, 24, 25 and 26, and <br />Response to Midterm Review <br />Dear Ms. Reilley: <br />As you know, our law firm represents Crosscreek Ranch, LLC, a neighbor of the King Coal <br />mining operation. Our clients consider King Coal a neighbor, and want to extend them <br />every courtesy as such. Crosscreek Ranch also hopes to be treated as a neighbor in <br />return. <br />We hope that you will consider this as a supplement to our previous correspondence on <br />this subject. <br />To reiterate, the company has been operating without the required local land use <br />permit. <br />It is a very interesting question how an operation of this nature has expanded so <br />dramatically without any kind of public review by any agency of government. <br />The dramatic changes in this permit have been improperly treated as Technical <br />Revisions rather than Permit Amendments, thus allowing them to proceed without the <br />public being aware, and without adequate public participation. <br />Colorado Revised Statutes says, at 34-33-103 (27); 'Technical revision" means a minor <br />change, including incidental boundary revisions, to the terms Or requirements of a <br />permit issued under this article, which change shall not cause a significant alteration in <br />the operator's reclamation plan." <br />