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operators describe the extent of disturbance and reclamation during the past year, as well as disturbance and <br />reclamation anticipated during the coming year, plus the dates that activities began and ceased, if applicable. <br />Since the Division does not require operators to provide "production" information on the annual reports, it has <br />been found that operators commonly do not include much "activity" information either, if no new acres are <br />affected or activities only consist of drawing down stockpiled materials. This seems to have been the case with <br />the reports filed by Hollenbeck, Inc. <br />While there may have been no new "extraction" or "mining" occurring during the years in question, even <br />sporadic or minimal sales of stockpiled material constitutes activity for that report year. In answer to your <br />recent concerns, Mr. Hollenbeck has sent the Division numerous statements and receipts from various parties <br />who purchased and/or hauled material from the pit. These documents reflect activity specifically during the <br />years 2002, 2006, 2007, and 2008. One of the statements received by the Division states that material has been <br />purchased intermittently "over the years" though it does not specify which years. Regardless of whether the <br />documents are inclusive of all such material sales and transport, they collectively demonstrate that there has <br />been ongoing activity at the pit. (Copies of the above-mentioned documents are enclosed herewith for your <br />information.) <br />As mentioned above, reclamation activity is also solicited from operators in the annual reports. It has been <br />observed and documented by Division staff the large amount of debris and contaminants present in the <br />Hollenbeck Pit. The several inspections and bond calculations account for the appreciable amount of removal of <br />these items during the years in question. Although Division records confirm it, the clean up activities, likewise, <br />were not reported in the annual reports. This may be attributed to the operator's desire for expediently filling <br />out the annual report or a misunderstanding of what types of activities are reportable. The reason that <br />"reclamation" as an onsite activity is included in this discussion is because of its inclusion in the language in <br />Rule 1. 13, which discusses Temporary Cessation. <br />Temporary Cessation (or TC) is a formal status reserved for permitted operations whose permits remain active, <br />though there are no onsite activities for periods exceeding 180 consecutive days. (Some permitted operations <br />may remain in "active" status, but are revised to allow intermittent activity, for their frequent periods of <br />inactivity which exceed 180 days. This revision is necessary when conditions require such periods, though there <br />may still be extractable reserves and have not yet reached the end of the life of the mine. However, when an <br />operation is not approved for intermittent activity, and it is expected to remain inactive for longer than 180 days, <br />the proper procedure is for the operator to revise the permit for intermittent activity or submit a statement that <br />the permit is going into Temporary Cessation. <br />Rule 1.13.1 discusses the question of whether a permitted site has reached the end of the life of the mine or <br />should be considered as being in TC. Rule 1.13.1 states, in part, that a permit will remain in effect as long as <br />there is extraction of material or the permit remains in compliance, or if construction materials still remain in <br />reserve. <br />Rule 1. 13.2 discusses what conditions may be considered when determining whether a permit should remain in <br />"active" status or should be placed in "temporary cessation" status. Rule 1. 13.2(5) states that a mine in TC does <br />not have sales of material or movement of stockpiled material. <br />Rule 1. 13.3(l) states that TC should not be considered for mines that are no longer producing, but which are <br />carrying out final reclamation activities. The clean up and other reclamation that was performed during recent <br />years is considered to be "activity," and as such, is further evidence of the ongoing "active" status of the permit, <br />and indicates it should not be in TC. <br />Pursuant to Rule 1.13.5, the duration of the status of TC may only last up to five years, at which time the <br />operator must request further time in TC from the Mined Land Reclamation Board, not to exceed another five