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c~ <br />'/ October 1, 1990 Letter Issues <br />~ The letter faxed on October 1, 1990 listed numerous omissions and <br /> discrepancies in the copy of the permit application reviewed by TREND. <br /> Several of these discrepancies and omissions were addressed adequately in <br />S' the MLRD permit application at the Division prior to issuance of the <br />~ proposed decision, but were apparently not updated in the MLRD permit <br /> application on file locally at the Trinidad, Colorado courthouse. Issues <br /> raised in the October 1, 1990 letter are addressed separately, below. <br /> Rule 2.03.8 - Permit Term Information <br /> The discrepancy in the acreage of disturbed land has been corrected to <br /> reflect all the changes. The total disturbed acreage approved is <br /> 19.78 acres. (See issue no. 1 above). The MLRD copy of the permit <br /> application was updated prior to issuance of the proposed decision, but <br /> the copy placed on file by the operator at the Las Animas County <br /> Courthouse in Trinidad, Colorado, was not. The operator has now updated <br /> the MLRD permit application found at the county courthouse. <br /> Rule 2.03.9 - P.I, and P.D. Insurance Information <br />Under Rule 2.03.9 P-I and P-D insurance is required prior to issuance of <br />a permit. The permit will not be issued until the required certificates <br />are submitted. <br />Rule 2.03.10 - Identification of Other Licenses and Permits <br />Rule 2.03.10 requires an applicant to identify other permits and licenses <br />that will be needed, but does not require him to obtain such permits <br />before seeking a reclamation permit. TREND's concerns assume that the <br />rule requires the applicant to obtain the other permits first, and that <br />the Division should evaluate the necessity and validity of the other <br />Dermits. In this case, the applicant identified a number of permits that <br />he has obtained, or will obtain prior to mining. TREND's individual <br />concerns can be addressed as follows: <br />(11 MLRD requested that all previously received permits be included in <br />Exhibit C. The applicant received a Class IV Special Use Permit <br />from the Las Animas Board of County Commissioners on July 10, 1987 <br />and this is shown as the first of seven permits issued under <br />Exhibit C. This special use permit is no longer valid. Prior to <br />initiation of operations as currently proposed, the operator will <br />need to obtain approval fora new special use permit from <br />Las Animas County. This is a county requirement, over which we do <br />not have jurisdiction. <br />(21 Notice of Intent X-87-202-00 did not relate to the 2 acre permit <br />site. The drill holes, 12 in all were spread over the entire <br />359.45 acres owned by the applicant. Only two of the original <br />holes were in the 2 acre site, and are in the present permit <br />application site. These holes are 29-1 and 29-8, and both were <br />later core drilled for coal analysis for inclusion in the present <br />permit application. <br />-3- <br />