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Mr. Fred Banta <br />February 15, 1990 <br />Page 4 <br />of these rules has resulted in a more rigid revision <br />process. Since the definitions of technical revisions and <br />minor revisions have not changed, it is apparent that the <br />change in interpretation is being precipitated by other <br />factors. It is not, however, being based on the specific <br />merits or complexity of the revision being requested. <br />We ask that you review this situation. It is our opinion <br />that a reasonable interpretation of the existing <br />definitions of technical and minor revisions would <br />alleviate most of the problems we are seeing. However, if <br />you feel the current application of the revision <br />definitions is necessary for compliance, a petition for a <br />rule change designed to clarify the revision process may <br />be appropriate. <br />Thank you for your consideration in this matter. If you <br />need additional information or clarification, please <br />contact me. Peabody appreciates the continuing <br />cooperation of the Division and we look forward to <br />resolution of this matter. <br />Sincerely, <br />l ~, James S. Lunan <br />Manager Permits <br />kjs <br />c: Mike Long - - --=~ =- <br />Gary Melvin - ---- <br />/Carl Mount <br />Susan Mowry <br />