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SO <br />50 <br />40 <br />N <br />20 <br />10 <br />0 <br />2003 2004 2005 <br />2006 2007 2008 2009 2010 2011 2012 2013 2014 <br />R Peabody Energy r Arch Coal Notes: <br />Cloud Peak initiated self-bondm;+n 2014. <br />Cloud Peak â– Alpha Alpha first d+sctosedself-bond Ingfor the year 2014. <br />Sourcr Company 104 f Ung$ <br />Figure: 2. Aggregate reclamation self -bonding reported by Peabody Energy, Arch Coal, Cloud Peak, and Alpha <br />Natural Resources, represented as a percentage of reported net worth. Data arrayed in Tables 3, 4, 5 and 6. <br />IV. VIOLATIONS OF SMCRA <br />Based on the aforementioned information, there is reason to believe that Peabody Energy <br />is in violation of SMCRA with regards to bonding at its permitted coal mining and reclamation <br />operations in Colorado, New Mexico, and Wyoming. Peabody Energy clearly no longer has a <br />history of financial solvency, rendering the company ineligible for self -boning under SMCRA <br />pursuant to 30 U.S.C. § 1259(c) and 30 C.F.R. § 800.23. In spite of this, Peabody has failed to <br />provide notification to state regulatory authorities that the company no longer qualifies for self - <br />bonding at its permitted operations, and to post alternate bonds within 90 days, a violation of 30 <br />C.F.R. § 800.23(g). Peabody's violations of SMCRA apply to the following permitted coal <br />mines: <br />11 <br />