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Since the second half of the Rule excludes the reference to technical revisions the Division has provided guidance that TR applications would not require a full description of the entire Permit area boundary. This Rule interpretation makes clear, logical sense because, unlike new permits, permit revisions and permit renewals, a new, renewed or modified permit boundary is not being proposed when considering a TR. Rather, a TR is being proposed to modify the mining or reclamation plan for a portion of the mining area contained within a previously described and approved permit boundary. Recognizing the clear difference between the overall intent of a TR process versus the more involved larger, comprehensive permit review process, the Division's guidance has been to require TR's to contain only a description of the lands to be specifically effected by the proposed change in the mining operation but not to require a complete re-publication of the entire description of the permit boundary. Any re-publication of the entire permit boundary description was reserved (correctly we believe) for the much larger permitting activities. In the case of Colowyo, and other large mines in northwest Colorado, a re-publication of the entire permit boundary descriptions for a simple TR would make little sense because the proposed changes are to occur within areas previously described and approved during one of the previous other major permit approval processes. Furthermore, many of the legal descriptions for the larger operations are so substantial and complicated that constant re- publication is a needlessly onerous and expensive endeavor. We should also not lose sight of the intent of the Regulations with respect to the public notice process. The intent is to allow, if not encourage, the public the opportunity to participate in the review process for coal mining activities. Publication of less complicated legal descriptions versus a full permit boundary legal description would certainly not limit public participation. In fact, publication of less complicated descriptions that more particularly describe the areas affected by the proposed revision are likely to be much more user friendly to the general public. The Division should also recognize that during Colowyo's 16 + years of publishing countless public notices in local newspapers we have received virtually no response from the local community. This being said, we see no justification for increasing the complexity of TR application public notices with additional requirements which are neither fully supported by regulation nor called for by a public clamor. We also believe that our request is consistent with provisions of the Colorado Surface Coal Mining Reclamation Act Section 34-33-116(3) which states that "the Board may promulgate regulations further defining the form and content of applications for technical revisions; except that applications for technical revisions shall not be subject to the full standards and information requirements applicable to new permit applications" The Division's request for full re-publication of the permit boundary in TR applications would appear to be in conflict with the Statute. Finally, we believe that our request is also consistent with the often stated intent of our State Government leaders to pursue the implementation of less onerous and more efficient regulatory requirements on the regulated community where possible.