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are available onsite, they might be approved for use as a growth medium. This substitute may be proposed as a technical revision, as well as any desired change in the revegetation seed mix. The item of most importance at this time is the proposed location of the western end of the affected area boundary. The new map shows a boundary which, while not extending very faz from the present toe of the dump, does extend outside the permit area boundary. The dump was expanded to that location by a former permitted operator. The affected area boundary is shown on Figure 1 to adjoin the permit boundary of the Carnation Mine, which makes good sense from an operational and reclamation perspective. It was stated in your letter that this western extension is onto lands controlled by IUC. For these reasons, it would seem a logical step to reco~gure the boundary of the Sunday Mine to what is shown on the new maps. Since the proposed line is outside the permit boundary (presently defined by the claim boundary, and shown in blue), it will constitute an addition of land. Additions of land to a permitted area generally aze accomplished through a pemtit amendment, which for Hazd Rock 112 permits cost $1,550. There is a different course for realigning the boundary that we might discuss, however, which is a blending of a technical revision and an amendment. It is allowed by Division policy, and is referred to as a "land exchange." It carves a technical revision fee of $150, and is a two-step process. If the boundary can be moved by releasing undisturbed land from the permitted area, and subsequently adding a similar amount of land to the permit, with no changes to the mining or reclamation plans, this method may be used. For example, this permit area includes several claims (consisting of many acres) north of County Road 20R. This area is sepazate from the rest of the mine/portal azea, and presumably will not be used in this operation. If a few acres could be released from the permit (through an approved acreage reduction request), then acres added back in the location needed outside the permit boundary, to meet the permit boundary of the Carnation Mine, it would accomplish what is needed. The last detail would be to demonstrate right-of-entry to those lands during the revision application process. As mentioned above, this land exchange method is a blend of rivo mechanisms: it carries the fee of a technical revision, but carries the required public notifications of an amendment. An amendment fora 112 permit requires four weekly publications of a legal notice, and then a 20-day public comment period. The content of the notice must include certain standard language, but may be made clearer (and perhaps less alarming) to the public by adding language explaining what is being applied for. Please contact me to discuss this process. Conversely, if the Carnation Mine permit area is expanded to fill that area, it will surpass 10 acres and therefore will become a 112 permit also. This is a "conversion," carries a fee of $1,875 and also requires public notices. Either method will work. GMG Mine -Figure 4 It was interesting to read about the closure, backfill and grading of the GMG Mine azea. What is to be done with the other features still on the site, such as cribbing and electric facilities? As mentioned above, pre-law features which have not been redisturbed in any way since the issuance of the permit, are not liable for reclamation. This may include the waste dumps, if they do not contain hazardous material and are not contributing to damage of the county road through sedimentation. The closure and grading will be "credited" against the reclamation liability. The seed mix used will be compared to the approved seed mix. If the one you used recently is different, and it is desired for the future revegetation of other areas of the permit, a revised seed mix may be applied for under a technical revision. The low earth berms onsite for controlling storrnwater do not impede livestock or wildlife, and presumably may be revegetated also. As such, they may (and probably should) remain after reclamation. Their removal will not be included in the bond calculation.