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and accidents, increased bankruptcies of junior and mid-level mining companies <br />in the 1990s, resulting in defaults of reclamation and closure bonds, have caused <br />most insurance carriers to Cancel policies and exit that specific market. In <br />addition, the long-term time frame associated with most mine recamation <br />obligations have caused surety interests to become wary and hesitant to <br />underwrite obligations extending beyond five years. Even large, active, well <br />Capitalized corporations such as PDC must now seek multiple and complex <br />venues, including collateralization of land and water assets, to fulfill ever- <br />increasing reclamation and closure FW requirements at state and federal levels. <br />Thus, this TR seeks to Garify and better define several areas in the Permit that <br />require formal revision in order to reduce the total FW and the significant <br />associated carrying costs. Henderson also has determined that a number of <br />other areas in the DMG estimated FW require clamcation and may result in <br />specific decreases and, possibly, several increases in the total. These <br />Gasifications do not fall within the definition of a TR and will be submitted to DMG <br />under separate cover. <br />3.0 THE TECHNICAL REVISION <br />As noted in Section 1.0, Henderson believes that there are several specific areas <br />to be addressed in TR-12. Each will be discussed separately in the order <br />presented. <br />• Reduction of Buffer Area Disturbance <br />• Structural Demolition - On Site Disposal <br />• Structures to Remain <br />• Tree and Shrub Planting <br />• Mine Water Treatment and Portal Plug <br />• Mobilization/Demobilization <br />3.1 Reduction of Buffer Area Disturbance <br />Buffer areas were established within the affected land area when the original <br />Permit was written to allow for facility expansions and disturbances in the future <br />without the need for a Permit amendment or TR. Buffers were not speafrcally <br />delineated, but estimated amounts were established generically for purposes of <br />FW determination. These areas were covered under the FW by an amount $1053 <br />per acre for reclamation. In the 25 years since the original Permit was approved, <br />3 <br />