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We would also note that the interpretation summarized by Item 4 is inconsistent with past practice for <br />this site, as various reclamation activities (le: Williams Fork Strip Pit, No. 9 Portals, Okie Plaza, and <br />No5 Portal) have been completed under Temporary Cessation, without changing the mine status or <br />triggering increased inspection frequency. <br />From a practical perspective, the approach of removing a site from Temporary Cessation status, and <br />implementing increased inspection frequency for reclamation activities, would appear to <br />counterproductive, since it would tend to discourage effective maintenance/remedial activities for <br />facilities and areas which no longer have any useful purpose, or which have deteriorated to the point <br />where they may represent a hazard. <br />Given the considerations summarized in this response, we respectfully request that the Division review <br />it's interpretation of the Temporary Cessation and inspection requirements, and clarify it's position, <br />with reference to the specific applicable regulatory provisions.