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the issuance of permit number C-81-013 in 2001 while such permit renewal did not conform to <br />SMCRA. You go on to change that the continued renewal of this permit was allowed while the <br />Certificate of Liability and Inswance was not in the name of the permittee, and that both the <br />State and OSM allowed the permit to remain in force. Lastly, you acknowledge that this <br />oversight is now corrected. <br />Informal Review: As provided by 30 CFR §842.11, you requested an informal review of the <br />DFD's decision on the TDN. Based on the information available tome, the facts of the situation <br />appear as follows: <br />1. Basin Resowces, Inc. is a corporation that was formed or registered on July 20, 1977 <br />under the laws of Colorado. <br />2. According to the OSM Applicant Violator System (AVS), ownership of Basin Resources, <br />Inc. was effectively transferred from Entech, Inc. to Westmoreland Coal Company on <br />Apri130, 2001. <br />3. The AVS further documents that changes in the Directors/Officers for Basin Resources, <br />Inc. also became effective on Apri130, 2001. <br />4. Westmoreland Coal Company is currently listed as the 100% owner of Basin Resowces, <br />Inc. in both the Golden Eagle Mine; Permit Number C-81-013 and in the OSM AVS. <br />5. The OSM AVS lists Basin Resowces, Inc. as the applicant and permittee of the Golden <br />Eagle Mine; Permit Number C-81-013 both prior to and after the aforementioned change <br />in ownership and control that became effective on Apri130, 2001. <br />6. Basin Resowces, Inc. was identified as the applicant and permittee of record for the <br />Golden Eagle Mine; Permit Number C-81-013 for the 5-year permit term renewals that <br />were approved by the DRMS both prior to and after the aforementioned change in <br />ownership and control that became effective on April 30, 2001. <br />On July 27, 2007, Basin Resowces, Inc. submitted Minor [Permit] Revision No. 8 ] to the <br />DRMS. The minor revision contained updated ownership and control information for <br />Westmoreland Coal Company including an organizational chart and a list of the current <br />Directors and Officers for the Golden Eagle Mine; Permit Number C-81-013, as well as <br />the dates on which they assumed their respective positions. <br />8. The DBMS deemed Minor Revision No. 81 to be complete be on August 6, 2007 and <br />subsequently approved it on August I5, 2007. <br />9. By letter dated August 20, 2007, the Agent for Peak Project Management (and consultant <br />for Basin Resources, Inc.) submitted to OSM for insertion into the existing permit the <br />updated ownership and control information contained in Minor Revision No. 81 for <br />Westmoreland Coal Company and, in particulaz, the Golden Eagle Mine; Permit Number <br />