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III IIIIIIIIIIIII III <br />999 <br />Snell &Wilmer <br />LLP <br />uw ofrices <br />1200 Seventeenth Street, Suite 1950 <br />TaborCenrer <br />Denver, Colorado 80202 <br />(303) Ci34.2000 <br />Fax: (303)634-2020 <br />REED `~`~`°~°° <br />- R1>FNLC AN¢ONA <br />DEC 2 ~ Z000 <br />TU6('RJ. ARUlRiA <br />Division o(Minerais and CeoloAY ~~~~ <br />Robett D. Comer (703) 634.2015 <br />Inremee n:omec®swlaw.com December 29, 2000 <br />VIA HAND DELIVERY <br />Mr. Mike Long <br />Division of Minerals and Geology <br />1313 Sherman Street, Suite 215 <br />Denver, CO 80203 <br />Mined Land Reclamation Board <br />1313 Sherman Street, Suite 215 <br />Dem'er, CO 80203 <br />Re: NOV # CV-2000-010 <br />Request for Extension of Time to Abate and Response to NOV ~ <br />Dear Mr. Long and Members of the Board: <br />SALT LAID: QIY, VfAH <br />This firm represents Powderhom Coal Company ("Powderhom"). Powderhor is a debtor <br />in possession having filed a petition in bankruptcy (Chapter 11) in the United States Banknlptcy <br />Court for the Eastern District of Kentucky. Powderhorn's bankruptcy case is administrated with <br />the bankntptcy case of its parent, Quaker Coal Company ("Quaker"), and 18 other subsidiaries of / <br />Quaker. <br />On December 14. 2000. Powderhom received a Notice of Violation from the Colorado <br />Division of Minerals and Geology ("DMG"), with respect to Reclamation Bond #108486 (the <br />"Bond") which Powderhom had obtained from Frontier Insurance Company ("Frontier") for its <br />mine located near Camco, Colorado (the "Powderhom mine"). The DMG based [he NOV on a <br />finding that the United States Department of the Treasury had revoked the certificate of authority <br />issued to Frontier pursuant to 31 U.S.C. §§9304-9308. The NOV states that to abate the <br />violation, Powderhom must replace the Botrd by January 16, 2001. The DMG warned that <br />failure to abate by January 16, 2001 would cause [he DMG to seek forfeiture of the Bond. / <br />By this letter, Powderhom responds to the NOV and seeks an extension of time in which <br />to abate the NOV. As set forth below, Powderhom respectfully submits that the delisting of <br />Frontier by the U.S. Department of the Treasury does not constitute a violation by Powderhom. <br />In addition, Powderhom requests that it be granted ninety (90) days from the date of the NOV, <br />i.e., until March 14, 2001, to resolve the issues identified by the DMG. Powderhor makes this <br />request because it cannot possibly meet the January 16, 2000 deadline. Powderhom's status as a't/ <br />6JSa.l <br />Snell S Wilmer is a member of Lrz mUNDI, a leading assnc moon o(mdependcm law toms. <br />