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necessity of reviewing all these aspects of the m�ning operation together so that the <br />interplay of factors may be seen and reviewed appropriately. <br />Additionally, although the Division did find that TR -24 was not a mining plan <br />modification, we believe that was an error and that it is such a modification under <br />CFR § 746.18 under the Surface Mining Control and Reclamation Act, (see subsection <br />(d), subsection (4)J, since the changes detected: in the Midterm review may extend coal <br />mining onto new leased Federal coal lands for the first time. <br />We would ask that the Division reconsider the determination that TR -23, TR -24, TR -25 <br />and TR -26 be considered as Technical Revisions. <br />We would ask that the changes contemplated in TRs 23, 24, 25 and 26 all be properly <br />considered together as a Permit Revision so that our client (and other citizens) have the <br />proper notification and comment periods in which to consider these substantial permit <br />changes. <br />Sincerely, <br />uke J. Danielson <br />cc: Mr. Daniel Hernandez, DRMS <br />Mr. Alan Boehms <br />Office of Surface Mining <br />Western Regional Coordinating Center <br />1999 Broadway, Suite 3320 <br />Denver, CO 80202 <br />Mr. Daniel Murray, Senior Planner, La F <br />Ms. Helen Mary Johnson, Bureau of Lai <br />Crosscreek Ranch, LLC <br />Ilata County <br />jd Management, Durango <br />