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2008-07-11_REVISION - C1992080 (2)
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2008-07-11_REVISION - C1992080 (2)
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Last modified
8/24/2016 3:34:34 PM
Creation date
7/11/2008 4:22:46 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1992080
IBM Index Class Name
Revision
Doc Date
7/11/2008
Doc Name
PAR Response
From
Savage & Savage
To
DRMS
Type & Sequence
RN3
Email Name
TAK
Media Type
D
Archive
No
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<br />A permittee may request reduction of the required performance bond amount upon <br />submission of evidence to the Division proving to the Division that the permittee's method <br />of operation or other circumstances will reduce the maximum estimated cost to the <br />Division to complete the reclamation responsibilities and therefore warrant a reduction <br />of the bond amount. The request and demonstration shall be in the form of a permit <br />revision application, or technical revision application, as appropriate. Bond adjustments <br />which involve undisturbed land or revision of the cost estimate of reclamation are not <br />considered bond release subject to procedures of 3.03. " [emphasis added] <br />It is our assertion that the Division is bound by the language of Rule 3.02.2(4) and <br />3.02.4(5;) and is required to evaluate the current costs of reclamation at the mine permit <br />area based on the current conditions and remaining reclamation requirements. It is our <br />request 'that the Division re-evaluate the calculated bond amount based on the current <br />conditions and remaining reclamation requirements at the Carbon Junction Mine and that <br />the permit renewal is an appropriate venue for such re-evaluation. Such a recalculation <br />would riot serve as a bond or liability release, only as a corrected recalculation of <br />remaining reclamation costs should the State be required to complete the reclamation <br />plan. <br />Please call me at your earliest convenience to schedule a meeting to discuss the items <br />above. <br />Sincerely, <br />Michael S. Savage <br />Principal <br />C: Sandra Pautsky, Oakridge Energy, Inc. <br />Bryan Duff, Goff Engineering & Surveying
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