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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
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20060862.tiff
BEFORE THE WELD COUNTY, COLORADO, PLANNING COMMISSION RESOLUTION OF RECOMMENDATION TO THE BOARD OF COUNTY COMMISSIONERS Moved by Chad Auer, that the following resolution be introduced for passage by the Weld County Planning Commission. Be it resolved by the Weld County Planning Commission that the application for: Case: Metropolitan Service Districts Planner: Kim Ogle, Chris Fellows be recommended favorably to the Board of County Commissioners. The Planning Commission recommends attention to suggested amendments in the following three areas:the cost of living index inflation clause; the issue of imminent domain with particular attention to open space;and that language in item 23 is consistent with state statute. Motion seconded by James Rohn VOTE: For Passage Against Passage Absent Michael Miller John Folsom Bryant Gimlin Bruce Fitzgerald James Rohn Chad Auer Tom Holton Doug Ochsner James Welch The Chair declared the resolution passed and ordered that a certified copy be forwarded with the file of this case to the Board of County Commissioner's for further proceedings. CERTIFICATION OF COPY I,Voneen Macklin, Recording Secretary for the Weld County Planning Commission,do hereby certify that the above and foregoing resolution, is a true copy of the resolution of the Planning Commission of Weld County, Colorado, adopted on July 19, 2005. Dated the 19th of July, 2005 OtUDA -nria Voneen Vl Macklin Secretary 2006-0862 WELD COUNTY METROPOLITIAN DISTRICT POLICY Weld County Planning Commission Presentation 07/19/2005 Prepared By: Fellows Financial, Inc. Project History A. First began preliminary discussions with staff& BOCC (Board of County Commissioners) mid 2004. B. Conducted initial workshop with County Staff in late summer 2004. Conducted a second workshop with County Staff and BOCC in the Fall of 2004. C. Formally engaged by County to proceed with Policy late 2004. D. Two further drafts and additional workshops with Staff E. Circulated the draft to three of the top special district firms in the State. We received their written comments and incorporated changes in a subsequent workshop. Another workshop with Staff and redraft of the Policy early 2005. F. Final review with Staff and some board members Spring 2005. G. Final draft in format presented today. What is Prompting the discussion? A. Predicted population Growth in Weld County: Year 2005 2030 Population 220,125 475,519 • Increase of 255,394 people • Increase of 116% • Additional 8513 people/year B. Not only a change in population but also a change in type of growth. Rural —> Suburban --*Urban C. New challenges, problems, issues 1. Infrastructure 2. Transportation 3. Schools 4. Services D. Special Districts are one tool, of many, to address these evolving challenges. 1. Financing 2. Economically Competitive Projects 3. Expands options available to County and to applicant. Background on Districts A. Started in 1949 B. Currently 2,234 special districts in Colorado C. District's services may include: 1 . Fire Protection 2. Parks & Recreation 3. Ambulance Services 4. Libraries 5. Water & Sanitary Sewer 6. Storm Drainage 7. Roads 8. Transportation 9. Mosquito Control 10. Security 11. Covenant Enforcement District Benefits A. Competitive Financing 1 . Better Rates 2. Lower risk / more viable projects 3 . Better Amenities B. Long Term / Perpetual Entity 1 . Maintenance 2. Operations 3 . Long term agreements / obligations C. Democratic —vs---- Unilateral Nature D. Quasi — Governmental in Nature Why have a Policy ? A. Communicate Weld County's Position 1) Fair 2) Clear B. Uniform Approach 1) Efficient 2) Equitable 3) Expedited C. Seamless 1) Comfortable and Understandable for Applicant 2) Comfortable and Understandable for Staff 3) Comfortable and Understandable for Planning Commission 4) Comfortable and Understandable for BOCC 5) Comfortable and Understandable for County Residents D. Consistent 1) Avoids appearance of being arbitrary 2) Level playing field from start Philosophy 1 . Make tools available for applicants and the County. 2. Minimize Risk A. County B. Future Resident / Homeowners C. Bondholders D. Applicants / Developers 3 . Encourages quality growth and enhances quality of life for County residents. Features of Proposed Policy 1 . Permits Districts 2. Permits Operations & Maintenance 3. Limits tiny, financially unstable districts ($2,000,000 A.V. test) 4. Requires demonstration of need for each power granted. 5. Description of I.G.A.s. 6. Limits on inclusions / exclusions 7. Limits on extra-territorial service agreements 8. Limits on Eminent Domain 9. Hard Cap — 50 mil, mill levy cap (includes O&M) 10. 35 mill issuance test 11. "Multiple — Districts" structure limitation 12. Limits on length of time for issuing debt 13. Provision for dissolution 14. District default controls 15. Model Service Plan Weld County District Policy A guide for Title 32 Special District, Metropolitan District and Service Plan Policy within Weld County, Colorado Whereas, Weld County is expected to undergo substantial growth over the next 30 years, and; Whereas, the County welcomes growth, it desires that the growth occur in an orderly, reasonable manner and that it is managed to insure the highest quality practicable to insure the quality of life for existing and future residents, and; Whereas, Weld County believes that Title 32 Special District and Metropolitan District financings, when properly structured, will enhance the quality of growth and the resulting built environment to occur in the County, and; Whereas, competitive and advantageous financing alternatives should result in competitive projects and optimize the affordability of new homes, provide for great communities, and confer a benefit upon all who live and work in Weld County. Now, therefore, the County of Weld establishes the following as its policy for the review and approval or disapproval of Service Plans, including any amendment thereof, of Metropolitan Districts and other Title 32 Special Districts (collectively "Districts"): 1. The County generally accepts the formation of Districts, where it is demonstrated that formation of the District is needed to provide public services or facilities to local development and will result in benefits to existing or future residents of the County and the District. 2. Districts will be permitted to conduct operations and maintenance activities where it can be demonstrated that having the District provide operations and maintenance is in the best interest of the County and the existing or future residents of the District. 3. District formation will generally not be favorably received where the future assessed value of all property within the District at build-out is projected to be less than $2,000,000. Special circumstances and special cause must be demonstrated for exceptions to be granted. 4. The District Service Plans submitted for approval to the County must comply with all State, federal, and local laws and ordinances with respect thereto, including specifically the Special District Control Act, Part 2 of Article 1, Title 32, C.R.S. (the "Act"). 5. Service Plans shall include all information required by the Act. 6. Service Plans shall enumerate and describe all powers requested on behalf of the District. Demonstration of the need or benefit of each such power is required. Granting powers, which are not clearly needed, will not be encouraged. 7. Any Intergovernmental Agreements ("IGAs"), which are required or known to likely be required, must be generally described, along with supporting rationale, in the Service Plan. 1 8. Service Plans shall include descriptions of any planned or likely inclusions into, or exclusions of property from the District's boundaries. 9. The Service Plan shall describe any planned extraterritorial service agreements. The District will be prohibited from providing any service outside its boundaries or from entering into any extraterritorial service agreements other than those listed in the Service Plan without the written permission of the Board of County Commissioners. 10. The Service Plan shall outline any anticipated needs or plans where it is planned that the District will need to use its power of eminent domain. The Service Plan will contain language, which limits the District to using its power of eminent domain to carrying out the District's essential functions and "Primary Infrastructure Plan". The Service Plan shall acknowledge that the District will need to receive approval from the Board of County Commissioners (BOCC) if it desires to expand its Primary Infrastructure Plan. The use of eminent domain will be undertaken strictly in compliance with State laws. 11. The Service Plan shall restrict the District's total mill levy authorization to 50 mills. This shall be a "hard cap", and it will be inclusive of both debt service and operations and maintenance mill levies. In no event shall these caps be exceeded. "Gallagher Adjustments"will be allowed on an annual basis. 12. The Service Plan shall include financial projections prepared by an investment banking firm or financial advisor qualified to make such projections which firm shall be listed in the "Bond Buyers Marketplace" as providing financial projections. The financial projections shall include calculations establishing the District's maximum debt capacity. These calculations must use market based, market comparable valuation and absorption data and shall not use an annual inflation rate greater than 3%. The projected maximum debt capacity shall be used as the "Maximum Debt Authorization" in the Service Plan, which shall not be exceeded without the written permission of the Board of County Commissioners and without a modification of the Service Plan. All debt election questions and related materials must be consistent with and in keeping with the "Maximum Debt Authorization". 13. The Service Plan shall provide for filing with Weld County of all formation election, debt authorization, and de-Brucing questions to be voted at any District election. Weld County shall have the right to deny any ballot question that is not in material compliance with the Service Plan prior to same being used in any such election. 14. Original issuance of bonded indebtedness by the District prior to build-out shall be limited to that debt which can be sized, serviced and defeased with no more than 35 mills for debt service purposes. 15. Multiple District structures are not generally encouraged. It is the intent of Weld County that "citizen/resident" control of Districts be encouraged to occur as early as possible. However, when the nature of a project requires a prolonged build-out period, and that "developer control" for an extended and commensurate period of time is needed to ensure that "developer financing" of the project and infrastructure continues, multiple District structures may be permitted. However, in such case, the Service Plan shall make provision to dissolve the multiple District structure or otherwise permit "citizen/resident" control at an appropriate time in the future. 2 In the case of projects with major commercial components, multiple District structures may be allowed to balance tax loads and protect future commercial owners/tenants from the disparate interests of a "resident" controlled District. The Service Plan must fully describe and articulate the need, reasoning, and mechanics any time a multiple District structure is proposed. 16. The District shall be limited to a series of debt issuances for a maximum of 15 years with a maximum maturity of 30 years for each series of debt. This restriction on issuance shall not pertain to refundings, which are necessary for the District's fiscal health nor shall it apply to refundings which result in a net present value savings to the District. 17. The Service Plan shall provide for the dissolution for the District once the Districts debts and financial obligations are fully defeased and once the District has completed all of its operations and maintenance responsibilities. A District with long-term, ongoing obligation for operations and maintenance will not be obligated to dissolve. However, the Service Plan must provide that in the event those obligations are someday undertaken by another party or are otherwise no longer the responsibility of the District, it shall be required to dissolve. 18. Attached to this Policy is a copy of the 'Weld County Model Service Plan". All Service Plans submitted to the County should follow the basic outline, form, sequence and structure of the attached Model Service Plan. Where possible, Service Plans should use the language contained in the Model Service Plan. Any unnecessary deviation from the form sequence, outline or language of the Model Service Plan may be grounds for denial. 19. In the event the District defaults on its debt, at any time, in any way, manner, shape, or form for more than 30 days, the District shall be precluded from issuing or refunding any additional debt of any kind whatsoever without receiving written permission from the Board of County Commissioners following a public hearing on the matter. 20. In the event the District defaults on its debt more than once for any amount of time, the District shall be precluded from issuing or refunding any additional debt of any kind whatsoever without receiving written permission from the Board of County Commissioners following a public hearing on the matter. 21. In the event that the District defaults on any of its other financial contracts, agreements, obligations of any kind on three or more occasions, the District shall be precluded from issuing or refunding any additional debt of any kind whatsoever without receiving written permission from the Board of County Commissioners following a public hearing on the matter. 22. Failure of a District to adhere to any of the conditions, restrictions, requirements, etc. contained in this Policy or in the approved Service Plan shall be a material modification of the Service Plan and shall carry whatever rights, remedies, and penalties which are available to the County or the electors of the District under the Act. 23. Weld County is receptive to District formation as an instrument to provide competitive financing for projects, build better and enhanced infrastructure, and where needed, create a quasi-governmental entity to provide essential and beneficial services which are 3 otherwise not available and which otherwise could not reasonably be provided. It is not the intent of the County to create multiple entities, which act in any manner, which could be construed as "competing governments". 24. Nothing in the Weld County District Policy is intended, nor shall it be construed, to conflict with or supercede, State, federal, or local laws or regulations. 25. This Weld County District Policy is intended as a guide only. Nothing in this policy is intended nor shall be construed to bind the discretion of the Board of County Commissioners which has, and shall retain, full discretion and authority regarding the terms and limitations of all District Service Plans and District formations. 4 Type of Local Government Number Municipal 271 County 64 Special Districts 2,234 Total 2,569 In comparison to other states, Colorado's state government is relatively small and limited in its power and resources. Conversely, in the absence of a large state government, Colorado has a strong and growing system of local governments, with over 2,500 units of local government. Local governments include counties, cities, school districts, and special districts Colorado's rank was 7th in the nation in the number of special districts. In 2002, only the following states had more special districts than Colorado: California, Illinois, Kansas, Missouri, Pennsylvania and Texas. Of our more than 2,500 local governments, at least four out of five are special districts. These range from fire, water, and sanitation districts to metropolitan districts -- districts that provide at least two types of services. Districts provide many valuable services such as ambulance and fire protection, libraries, and even cemeteries. Sources: The Colorado Department of Local Affairs and the Colorado Economic Futures Panel of Denver University. 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O M N O O O N M V CO to V r N N N N CO M V O O M C N N co r- r 04:.N N O O N r co r M O 0) CD V O r N N M CO O N N O O r CO to CO N N N r > n' d N N co- a a (o N O M tD N O O V N V CO V M O M N (D N N CD N N O O 0 u) >, V N V- N N V- N CO N r r r r U) r N N N N 1 r CD c U - w Ta o 0 W ' O O O r N O co r N CO N CO CO M V V V V N O V CO co N N N co o to __I O .J N O C) N CO CO CO CD N M c0 CO N CD to CO O CO CO O N M O to LO CO cr N V N O m W O O to r N r c0 Co O7 r O CO N N N CO V O V O O V O O LO Co N N N r 0 to c0 a0 O Lr < N N N V M 6C0 O N M M M N O M V V to V NtD N O N (o N t0 V M 0) C N Cl >, V to r N r r N on N N r r r r N N N W O H U N r 5 o O D Z to co D a) u .CO. N 'O Cl) C .E J N to c c L coC 0)o D1 ° N )= 0 a E Q o m m m °? o o) o `„ .a 5 d 2 m g , 2 o) E s iD m U z N co (6 N C 0 6° •-c 0 00 00 0 0 (p L Y.. O j O 0 00 f0 0 N N = a) a) = N 0- = JJJJJJ222222OOao_ aaaKc2ctu) u) C0C0C0r55 > 0 a) 0 o te (a u) I- WOODROW & SOBEL, P.C. ATTORNEYS AT LAW 1660 Wynkoop Street,Suite 1100 Denver,Colorado 80202 Telephone: 303-296-1400 Molly Sommerville Facsimile:303-296-1924 msommerville@woodrow-sobel.com E-mail: law@woodrow-sobel.com June 3, 2005 Via Telefax and Federal Express [1-970-304-6498] Chris Gathman, Planner Weld County Department of Planning Services 918 Tenth Street Greeley, Colorado 80631 Re: Frank Wright Property /Case Number: PZ-1074 Township 1 North, Range 68 West Section 5: S/2NW/4 (portion) Weld County, Colorado Dear Chris: This law firm represents Anadarko Land Corp. ("Anadarko Land"), formerly known as Union Pacific Land Resources Corporation, and Anadarko E&P Company LP ("Anadarko E&P"), formerly known as Union Pacific Resources Company, with respect to the application that has been filed with Weld County by Frank Wright for the approval of rezoning and a planned unit development for the property referenced above ("Property"). Anadarko Land and Anadarko E&P together own all of the minerals that underlie the Property. Enclosed is a letter to the members of the Planning Commission and the Board of County Commissioners for Weld County entitled "Notice of Mineral Interests Owned by Anadarko Land Corp. and Anadarko E&P Company LP and Objection" which I ask that you provide to the Planning Commission and the Board to be included in the record of the proceedings to be held on the application. As you are aware, C.R.S. § 24-65.5-101 et. seq. requires that developers give notice to mineral interest owners of hearings on applications for development and certify to the local jurisdiction that notice was given. Local governments are to require the certification as a condition for the approval of the application. Chris Gathman June 3, 2005 Page 2 Notices of hearings should be provided to the Anadarko entities as follows: Anadarko E&P Company LP Post Office Box 9149 Houston, Texas 77387-9147 Attention: Land Manager—Western Division/CBM Anadarko Land Corp. Post Office Box 9149 Houston, Texas 77387-9147 Attention: Manager, Property and Rights-of-Way Thank you for your consideration and attention to this matter. Very truly yours, WOODROW& SOBEL, P.C. Molly Sommerville MS/sa Enclosure cc: Tom Marranzino Dan Casper Don Ballard Donna Powers, Esq. Mike Tucker/ for EnCana Oil &Gas (USA) Inc. Frank Wright WOODROW 8c SOBEL, P.C. ATTORNEYS AT LAW 1660 Wynkoop Street,Suite 1100 Denver,Colorado 80202 Telephone: 303-296-1400 Molly Sommerville,Esq. Facsimile: 303-296-1924 msommerville@woodrow-sobel.com E-mail: law@woodrow-sobel.com June 3, 2005 Via Telefax and Federal Express Members of the Planning Commission of Weld County 918 Tenth Street Greeley, Colorado 80631 Members of the Board of County Commissioners of Weld County 915 Tenth Street Greeley, Colorado 80631 NOTICE OF MINERAL INTERESTS OWNED BY ANADARKO LAND CORP. AND ANADARKO E&P COMPANY LP AND OBJECTION Re: Frank Wright Property/Case Number: PZ-1074 Township 1 North, Range 68 West Section 5: S/2NW/4 (portion) Weld County, Colorado Ladies and Gentlemen: This law firm represents Anadarko Land Corp. ("Anadarko Land"), formerly known as Union Pacific Land Resources Corporation, and Anadarko E&P Company LP ("Anadarko E&P"), formerly known as Union Pacific Resources Company, with respect to the application that has been filed with Weld County ("County") for a change of zone and for a planned unit development by Frank Wright for property that consists of a portion of the S/2NW/4 of Section 5, Township 1 North, Range 68 West in Weld County ("Property"). The Anadarko entities own all of the minerals that underlie the Property. Members of the Planning Commission of Weld County Members of the Board of County Commissioners of Weld County June 3, 2005 Page 2 Anadarko Land and Anadarko E&P wish to give notice to the County of the mineral interests they own under the Property and object to the approval by the County of a final plat for the Property unless and until agreements on surface use are reached between the Anadarko entities and the Applicant with respect to the mineral interests. The following are comments in support of this Notice and Objection: 1. The Oil and Gas Resources Owned by the Anadarko Entities. The oil and gas interests owned by the Anadarko entities are the subject of oil and gas leases between a predecessor company to Anadarko E&P and a predecessor company to EnCana Energy Resources, Inc. ("EnCana"). EnCana operates four producing oil and gas wells on or adjacent to the Property that are located in the NE/4NW/4; NW/4NW/4 SE/4NW/4 and the S W/4NW/4 of Section 5. 2. The Hard Rock Minerals Owned by Anadarko Land Corp. Anadarko Land owns all of the hard rock minerals that underlie the Property, including the coal. A senior geologist with Anadarko Land has reviewed the Property for coal resource potential and determined that the Property lies within the Boulder-Weld Coal Field where there has been extensive coal mining in the past. The geologist opines that there are Laramie Formation coals under the Property that are approximately six feet thick and that lie at depths of approximately 110 feet. The Laramie Formation coals have a high BTU of approximately 8900 to 9800 btu/lb and a low sulfur content of between .3 and .8 percent. The geologist believes that there are approximately 1.6 million tons of coal under the NW/4 of Section 5. Enclosed is a copy of the pertinent portion of the Coal Resources and Development Map of Colorado which documents the numerous coal resources that underlie the Property. Members of the Planning Commission of Weld County Members of the Board of County Commissioners of Weld County June 3, 2005 Page 3 3. There Is Clear Statutory Authority and Direction for the County to Take into Account the Rights of Mineral Interest Owners in Its Consideration of Subdivision Applications. The State of Colorado recognizes the important rights of mineral owners and lessees in C.R.S. § 30-28-133(10) which states and acknowledges that both the mineral estate and the surface estate are interests in land and that the two interests are "separate and distinct." The subsection specifically recognizes that the owners of subsurface mineral interests and their lessees have "the same rights and privileges as surface owners." Further, C.R.S. § 24-65.5-101, et. seq. requires that applicants for development approvals give notice to mineral estate owners of hearings to be held before local jurisdictions for applications for development and further requires that the developer certify that he has given the required notice as a condition to the approval of the application by the local jurisdiction. 4. Government Action Which Allows Surface Development in a Manner Which Precludes Mineral Development May Impair the Vested Property and Contractual Rights of the Mineral Interest Owner. Colorado case law provides that the mineral owner has the right of reasonable access to and use of the surface estate to extract minerals and that the surface owner and mineral owner must exercise their rights in a manner consistent with one another.' Actions by a government entity which may have the effect of reversing this basic tenet of Colorado property law and thereby deprive the mineral interest owner of its vested property and contractual rights may violate federal and state constitutional provisions. Union Pacific Railroad Company gave a deed to William Hurley dated May 9, 1900 and recorded July 17, 1900 in Book 178, Page 401 in which the Railroad reserved the minerals for the Property. The Railroad granted the minerals to Union Pacific Land Resources Corporation by quitclaim deed dated April 1, 1971 and recorded April 14, 1971 in Book 644, Reception number 1565712. Applicant had record notice at the time he acquired his interests in the Property that the minerals were severed from the surface estate and that he received less than the entire interest in the Property. 'See Frankfort Oil Company v.Abrams 413 P.2d 190(Colo. 1966)and Gerrity Oil&Gas Corporation v. Magness,946 P2d 913 (Colo. 1977). Members of the Planning Commission of Weld County Members of the Board of County Commissioners of Weld County June 3, 2005 Page 4 5. An Action by the County to Approve the Application May Amount to a Regulatory Taking within the Meaning of the State and United States Constitutions. Action by the County to approve an application for surface development may constitute a regulatory taking, especially where the operator is deprived of all economically viable use of land or his investment-backed expectations to develop his property.2 The United States Claims Court and the Federal Circuit Courts have awarded compensation or affirmed decisions to award compensation to energy and mining companies based upon claims by the companies that their mineral properties had been taken by the government without just compensation because of government regulations which disallowed the development by the companies of their mineral rights.3 6. The Anadarko Entities Have Entered into Many Agreements with Developers With Respect to the Disposition of the Minerals at the Time that the Developer Proposes to Develop the Surface Estate, and the Public Interest is Sewed by the Parties Entering into Such an Agreement. The Anadarko entities have extensive mineral interests throughout Colorado where the surface estate and the mineral estate have been severed. The Anadarko entities have worked with many parties who wish to develop the surface estate in order to assure the compatible development of the surface and the minerals or to effect some other disposition of the minerals. The Anadarko entities wish to work with the Applicant in the same manner that they have worked with other developers. Toward that end, the Anadarko entities are in discussions with the Applicant to reach agreements which will include the oil and gas lessee. 2See, for example, Lucas v. South Carolina Coastal Council, 505 U.S. 1003, 112 S.Ct. 2886, 120 L.Ed. 2d 798 (1992). 3See for example Whitney Benefits, Inc. v. United States, 18 CI.Ct. 394(1989), corrected,20 CI.Ct.324(1990),affd., 926 F.2d 1169(Fed.Cir.),cert.denied, 112 S.Ct.406(1991); United Nuclear Corporation v. United States, 17 CI.Ct.768,affd.,912 F.2d 1432(1990). Members of the Planning Commission of Weld County Members of the Board of County Commissioners of Weld County June 3, 2005 Page 5 In the meantime, however, the Anadarko entities object to the Application until such time as they reach agreements with the Applicant with respect to their mineral interests and request that the County make any approval of a final plat for the Property conditioned upon an agreement between the Applicant and the Anadarko entities. Very truly yours, WOODROW& SOBEL, P.C. Molly Sommerville MS/sa cc: Donna Powers, Esq. Don Ballard Tom Marranzino Dan Casper Mike Tucker/ for EnCana Oil & Gas (USA) Inc. Frank Wright COLORADO GEOLOGICAL SURVEY Map Series 9 EXPLANATION LIGNITE WITH LESS TTUV(. L50: FT. (4fi.M.)" OF OY : LIGNITE WITH 150 FT. (46 Ft) TO L,000 FT" (305 Ft.)" OF-py SUBBITUMINOUS OR BITUMINOUS COAL WITH LESS THAN L% (46: M4.- . OF OVERBURDEN • SUBBITUMINOUS OR BITUMINOUS COAL WITH 150 FT. (46 14...1' TO a.ow Fr. (910 M.) OF OVERBURDEN BITUMINOUS COAL WITH MORE THAN 3,000 FT- (910 M.) OF OVERBURDEN gill ANTHRACITE AND SEMIANTHRACITE • AREA OF PAST OR PRESENT COKING-COAL PRODUCTION DENVER REGION COAL-BEARING REGION 42.47 ESTIMATED ORIGINAL IN-PLACE RESOURCES TO 6;000 FT. (1820 M. ) , IN 42.36 ESTIMATED BILLIONS REMAINING IN-PLACE RESOURCES TO 6,000 FT. (1820 M. ), IN BILLIONS OF TONS, AS OF 1/1/77 socilEji MINES AND PRELIMINARY 1977 PRODUCTION IN MILLION TONS (FOR MINES THAT PRODUCED > 0.2.5 MILLION TONS IN 1977) MI UNDERGROUND MINE (LICENSED AS OF DECEMBER 31, 1977) C ABANDONED UNDERGROUND MINE AN, SURFACE MINE (LICENSED AS OF DECEMBER 31, 1977) $NiA ABANDONED SURFACE MINE Harr* iy 3 r«ice aeav : 'G m Tj 3 ..-- - 1.----- .-41-411-1 tt min Tn ly Co er . C9 I.: I R�tr i ,�;H. , • 1 0 , I•.. Aan 1 m WI•asor • '. �', COB.me !. v�li�/ La•' • � — CO arev ellti.= BMne5 le _.. 'i� _ I 1 I n , 11� _ re e el'nd °"" t ills. V•ns 1 JCamol° � 1 ys .0 • unerOaonc • rOm x, 'x Uent • F anon ..I asto Ortnare n. 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