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Absence of any specific contention of violation, predicated upon assertion ore came from specific claims, supports the Petitioner understanding this was not a significant limitation. The significant limitation as explicitly stated, repeated within the permit, proscribes operation of mill as a custom milling facility and declares it will not process ores on a toll basis for other mining operations. If the limitation were attached to specific mining claims, then this proscription against custom or toll milling would have been entirely superfluous to the permit. If, however, it was contemplated additional claims and ores, owned by the operator/permittee were to be milled in the facility, then declaration of ownership without specificity as to the particular claims as accompanied by the prospecription against custom or toll milling, has definitive significance limiting the permit. For the foregoing reasons, Petitioner urges asserted violation by reason of milling ore owned by permittee, is not in violation of permit. 10. Act or Omission Not Willful: Original Permit No. M-83-141 was issued (1983) to permittee Gold Hill Mining Co. describing operation of the Cash Mine. In 1985, permit was amended to re-name applicant as Gold Hill Ventures Limited Partnership. The author signing on behalf of the operator Gold Hill Mining Co. (joint venture partner of Mi Vida Enterprises, then incompletely formed Steen family corporation) was Mark A Steen, signing for and on behalf of Gold Hill Ventures (joint venture partnership of Mi Vida and Cosmos). In fact, permittee was Gold Hill Mining Co., not Gold Hill Ventures. This was later corrected by the 1991 amendment that eliminated the non-existent Gold Hill Ventures Limited Partnership designation. The record reflects without exception, Gold Hill Ventures Limited Partnership does not exist in any form as a legal entity. While this unincorporated association was proposed by the Steen family, principally Charles Steen, Sr. and Mark Steen, as a prospective association of interests to develop and exploit certain mining properties located at Gold Hill, such association was never concluded. ~f O~~I In 1991, by request for transferal of mineral permit and 1 ~' I succession of operators, Gold Hill Mining Co. applied for assignment of e^^ permit from the permittee Gold Hill Mining Co. to co-permittees Gold ~ ~~, `~, Hill Ventures and Colina Oro Molino, Inc. (COM, Inc.). as successor operator to become successor permittee under Permit No. M-83-141. .~ ~~~~' 9