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and a list of the current Directors and Officers for the Golden Eagle Mine; Permit Number C-81-013, as well as the dates on which they assumed their respective positions. The DRMS deemed Minor Revision No. 81 to be complete be on August 6, 2007 and subsequently approved it on August 15, 2007. The DFD's September 4, 2007 response to the DRMS states that "OSM has reviewed the [5-yeaz term] permit approval documents for Permit No. C-81-013 and completed an Applicant Violator System (AVS) query." That review determined that Basin Resources, Inc. has wnsistently and continually been identified.as the applicant and permittee of record for the Golden Eagle Mine both prior to and after the change in ownership and control that became effective on April 30, 2001. In other words, Basin Resources, Inc. was the valid permittee of record prior to its sale to Westmoreland Coal Company and it remained the valid pemuttee of record thereafter. The sale of Basin Resources, Inc. did not require the DRMS to make a new decision regarding the permit itself. This was a situation where a subsidiary company (Basin Resources, Inc.) was sold from one parent company (Entech, Inc.) to another (Westmoreland Coal Company) where the subsidiary company's previous status as the valid pemilttee did not change. This is distinguishable from a situation where the new owner is transferring, assigning or selling its operations, including the permit, to another subsidiary company. You aze correct that Westmoreland Coal Company is the successor in interest. However; Colorado Rule 2.08.6(5) requires a new or revised permit application only when any successor in interest seeks to change the conditions of mining or reclamation operations, or any of the terms or conditions of the original permit. In this case, Westmoreland Coal Company did not seek to change the conditions of mining or reclamation operations or any of the terms or conditions of the original permit held by Basin Resources, Inc. It merely purchased apre-existing subsidiary permittee and changed the Duectors/Officers as a result of that purchase. Hence, an application for a new permit in the name of Westmoreland Coal Company for the Golden Eagle Mine; Permit Number C-81-013, in lieu of Basin Resources, Inc. was not necessary or required under Colorado's rules. Accordingly, Basin Resources, Inc. is the valid petmittee for the Golden Eagle Mine; Pernilt Number C-81-013 in compliance with Colorado Rule 2.08.6 and no violation occurred. Independent of this determination, nothing in the Federal regulations or Colorado's rules requires the holder of a permit to apply for a permit transfer. Specifically, 30 CFR 774.17 states that "[Njo transfer, assignment, or sale of rights granted by a permit shall be made without the prior written approval of the regulatory authority." The regulations establish requirements and criteria for the regulatory authority to approve an application for permit transfer. However, the regulations do not prescribe conditions under which a permit transfer must occur, only how the regulatory authority must respond once an application is filed. Colorado Rule 2.08.6 essentially mirrors the text of and is no less effective than 30 CFR 774.17. Thus, while we find above that Basin Resources, Inc. remains the valid permittee for the Golden Eagle Mine; Permit Number C-81-013, the absence of an application for a permit transfer does not equate to a violation of the State's