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h1RY Uc' "?I I5~~1 COLORRLG MIFIII'16 A551~1 3[3 6949415 <br />P. 2%3 <br />May {2, 1991 <br />Mr. Robert H. Hagen, Director <br />Albuquerque Field Office <br />Office of Surface Mining Reclamation and Enforcement <br />~ Suite 310 <br />625 Silver Avenue, SW <br />Albuquerque, NM 87102 REVIEW COPY <br />pear Mr. Hagen: <br />The Colorado Mining Association (CMA) has recently been informed t at the <br />i <br />Albuquerque Field Office (AFO) of the Office of Surface Mining Reclama ion and <br />Enforcement (OSM) may expect mine operators to maintain a copy of valid permits <br />and other records at a public facility in the county in which the ine is <br />located. <br />We believe it is appropriate to file copies of permit applications and r visions <br />at a local public facility during the pendency of such permit actions, but not <br />after the public comment period has elapsed and the permitting ac ion is <br />concluded. However, a letter could be filed advising an interested par y where <br />copies of such materials are available. <br />A requirement to maintain all such records after the permit action is c mpleted <br />is unnecessary and not mandated under Colorado's and OSM's regulatio s (cite <br />regulations here) for the following reasons: <br />1. Typically, the documents are filed with the county clerk, < <br />a public library or city hall might be viable alternativ <br />documents are generally voluminous and occupy substantial <br />Both the Moffat and Routt County (Colorado) Clerks have obj~ <br />holding these materials after the respective permitting ac <br />completed. Neither a coal operator, the state, or OSM has at <br />to require the local governments to hold such records. <br />though <br />The <br />space. <br />cted to <br />tion is <br />thorny <br />