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ACTION PLAN ID # U T-017-001 that the reduced costs of reclamation created by structure or building removal is not related to activities governed by Phase I, It or III bond release, the operator may be eligible for a bond reduction. Since 1983, OSMRE has consistently required that any reduction of the bond amount,for activities characterized as reclamation work performed, must occur through the bond release process. In 1983,OSMRE revised the language in 30 C.F.R. § 800.I5(c) "to clarify that bond adjustments which involve only undisturbed land or revision of the cost estimate of reclamation are not considered bond release subject to procedures of§ 800.40.s4 In the early 1990s, OSMRE addressed the issue of bond reductions subsequent to structure removal in Colorado. In 1991, OSMRE Headquarters provided an internal memorandum consistently deeming bond adjustments under 30 C.F.R. § 800.15 appropriate where justification for the bond reduction included changes to acreage to be affected or a permittee's showing that the reclamation cost estimate is "no longer valid for reasons other than the performance of reclamation work."5 The 1991 memorandum also explained that while "an argument could be made that performance of reclamation obligations reduces the cost of future reclamation,the structure of SMCRA, the language of the Federal regulation and the preambles to this rule clearly indicate that this is not the interpretation envisioned by Congress or[OSMRE]."b By implementing this section of Tech-007, DOGM inappropriately allows a bond reduction through bond adjustment procedures for the removal of structures from disturbed areas, rather than through the required bond release process. This not only conflicts with the SMCRA mandate at 509(e) and Federal regulations at 30 C.F.R. § 800.15(c),but also contradicts the approved State program requirements as the provisions mirror the Federal regulations at Utah Code Ann. § 40-10-15(5) and the Utah rules at UAC R645-301-830.430. Thus,bond reductions requested as a result of reclamation work performed must be processed as an application for bond release under 30 C.F.R. § 800.40. The request cannot be approved unless the criteria specified in 30 C.F.R. § 800.40(c) and section 519(c) of SMCRA, or in DOGM's case, the Utah rules at UAC R645-301-880, are satisfied. Moreover, SMCRA and the Federal regulations distinguish between instances where the operator revises its reclamation plan to replace a structure on a disturbed area and where a structure is simply demolished under an approved reclamation plan. When an operator submits a permit revision application to alter the reclamation plan, such as to replace one structure with another or to construct a materials storage area on a former building pad,the costs of future reclamation may change and the bond amount may be properly adjusted to reflect the changing costs of future reclamation. In this case,the area is still considered a long-term facility and is not subject to contemporaneous reclamation requirements until it is no longer needed in support of mining or d 48 Fed.Reg.32945(July 19, 1983). 5 OSMRE Internal Memorandum at 1 (Jan.9, 1991). 6 Id.(clarifying that"To be approved under the bond adjustment provisions of 30 C.F.R. § 800.15(c),a proposed bond reduction must be justified solely upon either changes in the acreage to be affected(not the acreage remaining to be reclaimed or a demonstration that the reclamation cost estimates upon which the current bond amount is based are no longer valid for reasons other than the performance of reclamation work. Any bond reduction requested as a result of reclamation work performed must be processed as an application for bond release under 30 C.F.R.§ 800.40 4