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<br /> <br />As confirmed in a letter from counsel for EFC to the Mined <br />Land Reclamation Division ("NERD") dated January 16, 1981, the <br />fact that the permit application supporting EFC's existing Per- <br />mit No. 79-177 was found to be in compliance with the Permanent <br />Federal Regulatory Program at a point in time prior to the ap- <br />proval of the Colorado Regulatory Program entitled EFC to effect <br />compliance with the Colorado Program under S.R. 2.01.3(5) by <br />submission of additional materials addressing substantive dif- <br />ferences between the Colorado and Federal Regulatory Programs. <br />After careful analysis, Colorado Yampa has identified only <br />5 areas in which substantive differences exist between the re- <br />quirements of the Colorado Regulatory Program and the informa- <br />tion contained in the permit application for Permit No. 79-177. <br />Colorado Yampa emphasizes that in many instances the information <br />contained in the permit application actually went beyond that <br />required by the Federal Permanent Program Regulations and thus <br />certain differences between the two sets of regulations have al- <br />ready been addressed in the existing permit application. In <br />order to avoid redundancy, Colorado Yampa therefore has addres- <br />sed only those actual differences between the permit applica- <br />tion, as supplemented in the course of the permit review pro- <br />cess, and the Colorado Rules. <br />Colorado Yampa has set forth below the language or the <br />heading of the Federal Regulation, followed by the language or <br />-2- <br />