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EFCI has modified the existing approved permit through the mechanisms of <br />both technical and minor revisions as required to reflect new information <br />and advances in mining methods, and to meet changing operational needs. <br />EFCI also worked closely with the CMLRD through the mid-term review <br />process and more recently, in renewing the permit and developing the <br />comprehensive permit revision represented by this submittal. <br />It should be noted that the baseline data and related analyses presented <br />in this permit revision document were collected/completed under regulatory <br />provisions applicable at the time the work was performed. With changing <br />regulatory requirements, certain information may not be totally consistent <br />with current regulations. To the extent possible, EFCI has modified the <br />permit information to fully comply with current regulatory provisions. <br />Where such modification were not practical, the information presented <br />reflects the regulatory criteria in effect at the time of original <br />approval and brief clarifications are provided as appropriate. <br />• 2.01.4 PERMIT REQUIREMENTS FOR NEW SURFACE COAL MINING AND RECLAMATION <br />OPERATIONS <br />EFCI is operating under an existing valid permit issued under provisions <br />of the Colorado regulatory program. As the permit has been modified or <br />revised, revisions have reflected regulations applicable at the time. <br />2.01.5 PERMIT TERM <br />The existing approved permit (Permit No. C-014-81) expired on July 30, <br />1989. EFCI is currently continuing operations under the existing permit <br />as provided for by the provisions of Section 2.08.5, Right of Successive <br />Renewal. Application for renewal of the Southfield Permit was filed on <br />January 26, 1989 and review of the renewal application is currently in <br />progress. Upon renewal, the permit will be extended for a successive 5 <br />year term. <br />• <br />2.01-2 <br />