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III IIIIIIIIIIIII III y <br />STATE OF COLGw-~uU <br />Roy Romer, Governor <br />r rn <br />~ (%ti <br />DEPARTMENT OF NATURAL RESOURCES <br />MINED LAND RECLAMATION DIVISION <br />FRED R. BANTA, Dlractor <br />February 7, 1989 <br />Mr. Jonn Kezer, Commissioner <br />Division of Insurance <br />303 W. Colfax Avenue, Room 500 <br />Denver, Colorado 80204 <br />RE: Self Insurance of Eastern Gas and Fuel Associates, Blue Ribbon Mine, <br />Red Canyon Mine, Mo. Thompson Creek Mine <br />Dear Mr. Kezer: <br />I nave received a recent request to allow self-insurance at three coal mines. <br />I am unable to evaluate this request and therefore would appreciate assistance <br />from your staff in evaluating this proposal and answering some questions. <br />Eastern Gas and Fuel Associates (Eastern) is the parent corporation for three <br />coal mining operations in Colorado. All such operations are required to <br />demonstrate that they have adequate insurance coverage in accordance with <br />C.R.S. 34-33-110(5). The amount of coverage required by Rule 2.03.9(1} of our <br />regulations is as follows: bodily injury shall be $300,OD0 for each <br />occurrence and $500,000 aggregate, property damage shall be $300,000 for each <br />occurrence and $500,000 aggregate. Copies of the applicable sections of the <br />Act and our Regulations are attached for your information. <br />Eastern has submitted to us a Certificate of Insurance which indicates they <br />have $1,500,000 in coverage. However, the Certificate also indicates that the <br />first 500,000 is covered by self-insurance (see attached copy of Certificate). <br />Based on these circumstances I nave the following concerns: <br />1. What are the State or Federal self-insurance requirements. <br />2. Does the Certificate and correspondence from Eastern meet those <br />requirements. <br />3. Does the $500,000 level of self-insurance apply to each of the <br />three operations? <br />Any assistance you or your staff can provide would be greatly appreciated. If <br />you have any questions feel free to call me. <br />Sincerely, <br />~~ <br />Susan J. M1 w y <br />Senior Reclamation Spec'al st <br />215 Centennial Building, 1313 Sherman Street <br />Denver, Colorado 80203-2273 Tel. (303) 866-3567 <br />Z10 R^ <br />