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ene~~~ ~ue1s c®~perat~or~ ~ O~ s ~ executive offices • suite 900 • three park central • 15t6 arapahoe • denver, Colorado 80202 • (303) 623-8317 April 15, 1981 Mr. Gerald Magnuson Alternate Regional Coal Team Chairman Bureau of Land Management Utah State Office 136 East South Temple Salt Lake City, Utah 84111 o i ~r,~~?~?~~ n ~.I I~I'1'( Ar'R Z 7 1981 i~: L7r~~lt L . ~[fAU1p LNt ~( luu un:,L 11CJU m.~W Re: Pinnacle Tract Lease Sale - Proposed Lease Form Dear Mr. Magnuson: This letter is written to express the strong objections of F~nergy Fuels Corporation ("Energy Fuels") to portions of Section 6 and 31 of the proposed Coal Lease C-29220. As you know, Coal Lease C-29220 will be offered for competitive lease sale on April 30, 1981. In general, Energy Fuels objects to those portions of Coal Lease C-29220 which, in its view, seek either to alter the legal rights of the prospective lessee through contractual lease provisions or to empower the Bureau of Land Management (r'BLM") or the Colorado Division of Wildlife ("DOW") with approval powers which neither the BLi4 nor DOW would otherwise possess in the absence of the lease provisions. It is the hope of Energy Fuels that the specific objections set forth below will be seriously considered by the Green River-Hams Fork Regional Coal Team prior to the April 30, 1981 lease sale and that Coal Lease C-29220 will be altered in accordance therewith. In the comments which follow the objectionable provision will be identified, followed by a brief discussion of the objections of Energy Fuels to that provision. Lease Provision - Section 6. PRODUCTION ROYALTY: "...The royalty rates provided in this section shall not be subject to revision except in the course of lease readjustment." OBJECTION: The effect of this provision is that the royalty rate set forth in the lease may be revised only on the 20th year after the effective date and on each 10th year there- after, in accordance with Section 23. Energy Fuels is