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Lorenci[o Canyon Mine <br />April 11, 2001 <br />Page 3 <br />Revision was discussed and agreed during our December 12, 2000 meeting with AEI and <br />Greystone personnel. The need for a Perini[ Revision is also acknowledged in the <br />Greystone/A.P. Maxwell letter of November 29, 2000. <br />Additionally, A.P. Maxwell recently conducted site resource exploration [o define coal <br />resources and i[ is our understanding that A.P. Maxwell remains uncertain as to the nature of <br />the coal resource, and how the resource might be mined. Extensive regulatory flexibility <br />was exercised by DMG to allow the exploration activities to proceed expeditiously. <br />Based on our understanding that the mining and reclamation plan contained in the <br />previously approved and expired permit C-96-084 is no longer viable, we must reiterate our <br />position that if the permit is reactivated, a Permit Revision, rather than a series of Technical <br />and Minor Revisions, must be submitted. Such a submittal cannot be formally accepted for <br />review until the expired permit No. C-96-084 is reactivated for good cause, in accordance <br />with 2.01.5(2). The Permit Revision is needed to ensure that the new mining and <br />reclamation plans will be in full compliance with the Act and the Rules. Full compliance <br />includes an evaluation of the mining and reclamation plan, and all associated impacts and <br />mitigation plans. An adequate bond amount must also be determined. Mining and <br />reclamation cannot commence at the proposed Lorencito Canyon Mine until all required <br />permitting is complete, and the required bond is submitted. <br />Given the apparent uncertainty regarding the manner in which mining and reclamation may occur, <br />we must ensure that the mining plans are comprehensive and complete by requiring a Permit <br />Revision. A fragmented permitting process is not acceptable. Please provide to DMG the <br />information needed to reactivate the permit, and the required Permit Revision as soon as possible. <br />Please feel free to contact me with any questions. <br />S <br />Supervisor <br />Cc: Mike Long <br />Dan Hernandez <br />Kent Gorham <br />lon:nc¢o kitty april l L <br /> <br />