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SUMMARY OF THE REVIEW PROCESS
<br />On July 30, 1980, Kerr Coal Company submitted a permit application document to the Colorado
<br />Mined Land Reclamation Division and to the Federal Office of Surface Mining to continue and
<br />expand its existing operations at the Marr Mine site. The application was assessed as complete
<br />on August 27, 1980, and a findings document was issued on January 13, 1981, with 12
<br />stipulations. The permit document was issued on March 20, 1981. The Division prepared a mid-
<br />term review on February 28, 1984, and Kerr Coal Company responses came in on June 14, 1984.
<br />On September 18, 1985, Kerr Coal Company submitted their first permit renewal application
<br />(RN-01) for the second permit term. The Division responded with an adequacy letter on
<br />December 31, 1985. A findings document with seven stipulations was issued on April 24, 1986.
<br />The renewed permit was issued on July 10, 1986.
<br />On October 2, 1986, specific findings were re-written regarding the bond. Kerr Coal Company
<br />requested a formal hearing on the findings and accompanying stipulations. The Mined Land
<br />Reclamation Board and Kerr Coal Company ultimately signed a settlement agreement on
<br />February 25, 1987, which required a bond of $5,500,000 for the existing disturbance.
<br />On September 20, 1990, Kerr Coal Company submitted a permit renewal application (RN-02)
<br />for the third permit term. The Division presented preliminary adequacy concerns on October 3,
<br />1990. After a series of adequacy reviews, the Division issued its proposed decision to approve
<br />the RN-02 application on December 9, 1992. Also on this date, specific findings were issued
<br />concerning the renewal.
<br />During the early part of 1993, the Division and Kerr Coal Company evaluated the reclamation
<br />liability at the mine site and determined that the $5,500,000 bond was sufficient.
<br />On March 18, 1994, Kerr Coal Company submitted a request for a bond release (SL-01). This
<br />was a Phase I bond release request for the 720 Pit, the associated former overburden stockpile
<br />area, and Pit 1.
<br />The Division prepared a mid-term review on August 17, 1994. The Division did not require any
<br />permit modifications at that time, beyond those that were being addressed through Bond Release
<br />Request No. SL-O1, submitted on March 18, 1994.
<br />On September 22, 1995, Kerr Coal Company filed a complete application for a permit renewal
<br />(RN-03) for the fourth permit term. On March 25, 1996, the Division sent its adequacy review
<br />letter to Kerr Coal Company, identifying those items found deficient. On the same day, Kerr
<br />Coal Company submitted to the Division a request for an extension of the Division decision due
<br />date for RN-03 to April 30, 1996. Kerr Coal Company submitted its responses to the Division's
<br />review on May 2 and May 10, 1996, accompanied by a request for an extension to June 14, 1996.
<br />The Division concluded its review of the Kerr Coal Company responses and approved the RN-03
<br />permit renewal application on May 14, 1996.
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