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every 2'~ years for adequacy it would be inappropriate for the <br />phased bond release procedures to be more onerous that the <br />comparable federal regulations. <br />Other Regulatory Chances <br />Other Colorado regulations more onerous than the counterpart <br />federal regulation include Rules 4.15.8 Revegetation Success <br />Criteria and Rule 4.16 Postmining Land Use. Review of these rules <br />in comparison to comparable federal regulations raises a number of <br />questions as to the reasons for the Colorado rules being more <br />onerous in certain sections. In conversation with Dan Mathews, I <br />suggested that these more onerous sections of the Colorado rules <br />may have been written at a time when mining impacts to local <br />wildlife populations were uncertain. There is general agreement <br />that these earlier perceptions were wrong and our present knowledge <br />regarding wildlife population around coal minas hav+a changed. I <br />suggested further that those Colorado regulations that are more <br />onerous that the federal counterpart due to these misconceptions <br />regarding wildlife impacts should now be changed to regulatory <br />language no more onerous that the federal regulations. <br />Please contact me if we can be of assistance in this matter. <br />Sincerely, <br />Tames A. Kiger <br />Sr. Environmental Specialist <br />JAK/gdf <br />xc: R. G. Atkinson <br />Central Files <br />