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Page six <br />SUMMARY <br />This analysis presents the reasons why'the Soard should not suspend <br />or revoke the permit to mine at the Golden Eagle Mine. These reasons can <br />be summarized as follows: <br />1. Basin received the referenced NOVs as a result of a combination of <br />events which culminated in March 1993. These include changes in <br />enforcement policy as a result of political changes in program <br />implementation on the State and Federal level due to liability created by <br />other mining operations, reinterpretation of regulatory requirements <br />which created the necessity for additional design and documentation, <br />failure to maintain facilities by both Basin and the previous owner, and <br />failure of the Division to implement direction on several of these items <br />over the past several years. <br />2. Basin responded to abate and terminate the NOVs as quickly and <br />efficiently as ,possible given the number and nature of the tasks. This <br />included the commitment to achieve regulatory compliance by hiring <br />additional environmental staff as well as contract labor. These <br />commitments have been fulfilled. <br />3. Six of the ten NOVs are currently terminated and the other two are <br />in the final phases of termination. As a result, the operation. is in <br />compliance with the rules and regulations of the State program. <br />4. Basin has implemented a regulatory compliance program to prevent a <br />similar situation from developing in the future and is in the process of <br />formalizing this plan by the use, of engineering inspections, record <br />keeping, appropriate maintenance and' follow up, and third party <br />auditing. <br />5. Basin has acquired a long term coal contract and is committed to <br />long term environmental and regulatory compliance. This compliance will <br />ensure environmental protection as well as economic benefits to <br />individuals employed at the mine as well as Las Animas County. <br />Should you have questions or need additional information concerning <br />any of the information presented herein, please do not hesitate to let me <br />know. We appreciate this opportunity to provide this information and <br />look forward to working 'with the Division in the future to achieve <br />regulatory compliance. <br />Sincerely, <br />Earl R. White <br />President and General Manager <br />