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<br />Table 2.) Acreaee Cateeories as the Operator has Renorted in Technical Revision 04 <br />'Acreage Cate ories <br />Permit Area <br />2760. Key Revisions <br />2760 <br />2760 <br />(operator) Affected Area 150 150: : •.300 ` ; . <br />'Original Operation Bonded. Area 224 ?? 224 <br />Added' Bondin Boundary Area 329 <br />----- ------------------ ??? 300. <br />DRMS Bonded Area 250 250 250 <br />Based on:these, definitions and acreages, there are several issues that need to be addressed <br />anddefinitions that will need to be:clarified. <br />Issue #X: Bond%ngBoundary's Amounts <br />There is a discrepancy in the numbers of acres that are currently approved:inthe.,., <br />"bonding boundary" acreages. The original "bonding boundary" " area prior to ' <br />Amendment 03"was224 acres. The "bonding boundary" area -added in Amendment 03 <br />area was:321 acres yielding a,total "bonding boundary" of 545 acres. During Technical <br />Revision 03; .15.9 acres, were removed from the Amendment 03 "bonding boundary" area _ <br />leasing 305:1:acres:bonded"for that area. `This 15.9 acres was then added to the "origmal` <br />bonded area". increasing the area from 224 acres to 239:9 acres. In TR04 it does:not. . <br />appear that TR03 acreages were taken into account. In regard to the current Technical, <br />Revision request, from the Division's point of view there should be. 284.1 acres in. the <br />Amendment `.03 ".`bonding boundary" area after removing the 21 acres and there Ishould <br />still be239.9acres in the "original bonded area" yielding a total of 524 acres.'still in. the <br />"Bonding Boundary :area. The acreages in.the Technical Revision 04 submittal do not <br />match these, numbers. Please clarify these discrepancies. <br />Issue #2: DRMS Bonded Area versus Bonding Boundary <br />The current financial warranty`heId by the, Division is based, on, a disturbed area amount,,: <br />of 256 acres. Overall, it does'not appear that the so called `Bonding Boundary" is <br />actually the area•that is c"urgently bonded fori.e. we do not havea bond in place,for:524: <br />acres but for 250 ,acres: Based on your definition of "Bonding Boundary",.the area that is.. <br />currently, bonded by`the Division does are not equal this amount, the reason for this may <br />lay. .in the stepped" bonding method described in the Amendment 03 application :However <br />his is unclear; if more land is to be affected than 250.acres, "the .bond; will `need to be <br />adjusted.. Or, the definition of Bonding. Boundary may need to be updated; changed or. <br />clarified. ' <br />Issue'#3:;0perat6r allowed Affected Land, Bonding Boundary and the Divisions <br />Bonded Area <br />Based. onthe` Amendment 03 application, it states on page 13 of the mining plan, that "rio <br />more than 150 acres of mining activity be disturbed at any one time." This acreage ' <br />amount did not include the access roads or land that has.beeri final graded, and "placed in <br />. <br />3