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• In a meeting between the CMLRD and EFCI representatives on October 4, <br />1989, the CMLRD indicated reservations based upon administrative <br />constraints in approving any revisions to an expired permit under <br />"Administrative Relief". These concerns apply to both the proposed permit <br />boundary revision and an outstanding revision for expansion of the <br />existing coal refuse pile. Given the CMLRD's concerns and EFCI's <br />immediate needs, the CMLRD suggested and EFCI agreed, to proceed with <br />responses to critical renewal issues in order to renew the existing <br />permit, with completion of the permit update and reorganization stipulated <br />as a condition of renewal. Upon renewal of the existing permit, the CMLRD <br />agreed to expedite review and approval of the required permit boundary and <br />refuse pile expansion revisions. <br />Immediate operational needs will be addressed by timely approval of the <br />noted permit revisions. However, continuing operations and ongoing <br />compliance are directly related to approval of the operation and <br />reclamation plans presented in this permit revision submittal. <br />• <br />No significant adverse mining related impacts are anticipated. In <br />addition, socioeconomic impacts are expected to be primarily positive and <br />will be essentially the same as for existing operations. All mine <br />facilities are already in place and will continue to be utilized over the <br />remaining mine life. No additional surface disturbance is contemplated <br />and consistent with existing plans, all disturbed areas will be reclaimed <br />upon completion of mining. <br />If EFCI is to continue operations at current levels and maximize recovery <br />of available mineable reserves there are no feasible alternatives to the <br />plans presented in this revision submittal. EFCI therefore, respectfully <br />requests that the CMLRD approve this revision application and the <br />operations and activities described herein. <br />Since purchasing the mine in 1985, EFCI has worked closely with the CMLRD <br />to meet continuing operational permitting needs, and maintain effective <br />. regulatory compliance. EFCI hopes that the CMLRD's familiarity with the <br />Southfield operations and the cooperative relationship which has been <br />established will facilitate and expedite the review/approval process. <br />10 <br />