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<br />the scheduled conference. The public notice, which announced the time and purpose of the <br />informal conference, was published on August 25 and September 1, 1999. <br />The second informal conference was held on September 13, 1999, to discuss the issues in Permit <br />Revision No. 3. As at the first informal conference, the Division answered questions and <br />received further comments from the public concerning the changes proposed in BRL's mine <br />plans. The Division sent its adequacy responses to BRL's August 30, 1999 letter on September <br />24, 1999. <br />BRL answered all of the Division's adequacy questions for Permit Revisions Nos. 2 and 3. The <br />Division proposed to approve with conditions Permit Revision No. 2 on September 13, 1999. On <br />October 12, 1999, the Division received objections to the proposed decision and a request for a <br />formal hearing. The proposed decision to approve Permit Revision No. 2 was brought before the <br />Mined Land Reclamation Board (Board) on October 20, 1999. The Board approved the <br />Division's proposed decision to approve with stipulations Permit Revision No. 2 on that same <br />date. <br />On February 1, 2000, the Division proposed to approve with stipulations Permit Revision No. 3. <br />No requests for a board hearing were received at the Division. Therefore, the decision became <br />final on March 2, 2000. <br />The Division received the submittal for Permit Revision No. 4, dated October 5, 2000, on <br />October 6, 2000. After reviewing the submittal, the Division determined that the information was <br />incomplete. Therefore, the Division notified BRL, in a letter dated October 16, 2000, what <br />information was needed to call the submittal complete. BRL included that information in a <br />submittal dated October 18, 2000 and received at the Division on October 19, 2000. The Permit <br />Revision No. 4 submittal was called complete on October 23, 2000. Notification letters of the <br />completeness were mailed to federal, state and local governmental agencies, as well as to local <br />water user and concerned environmental organizations. The public notice of the revision's <br />completeness was published in the Delrn County Ltdependent for four consecutive weeks, <br />starting on October 25, 2000 and ending on November 15, 2000. <br />In a letter dated October 27, 2000, the Division requested that the Office of Surface Mining <br />(OSM) make a determination as to whether Permit Revision No. 4 constituted a federal mine <br />plan change requiring Secretarial approval. In a response letter, dated November 1, 2000 and <br />received at the Division on November 6, 2000, OSM confirmed that [he activities proposed in <br />Permit Revision No. 4 do constitute a federal mine plan change requiring Secretarial approval. <br />The Secretarial approval would be decided after the Division issues its proposed decision on the <br />revision. <br />The Division sent its first adequacy review letter on November 8, 2000. In that letter, the <br />Division requested additional information for the Identification of Interests section of the permit <br />application. Also, as part of the adequacy review process, the Applicant Violator System (AVS) <br />linked several violations and forfeitures with BRL, either through associations within the <br />corporate hierarchy or through past company associations by the present officers or controllers. <br />The violations and forfeitures were all part of settlement agreements, so the recommendation was <br />3 <br />