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• David Bird, the Division's Reclamation Specialist, testified the August 2010 Order meant <br />that "Cotter needed to have by August 31st dewatered the mine down to the 500 foot <br />level below the Steve Level." AR:0204:9 -15. <br />• Board Member Randall characterized the corrective action as "a performance standard." <br />AR:0217:17 -18. "It's thou shalt reinitiate mine dewatering and water discharge treatment <br />sufficient to bring down the mine water table to a level 500 feet below the Steve Level by <br />date certain." AR:0217:18 -21. <br />• Board Member Randall separately opined that the August 2010 Order "required only that <br />Cotter `reinitiate' and begin `implementation' by August 31, 2010." (Joint Answer Brief <br />at 32, citing AR:0208 -10) (emphasis added). <br />• Later in the Hearing, Mr. Bird changed his interpretation, stating that the August 2010 <br />Order recognized Cotter "can't start dewatering tomorrow," and "implementation is a <br />step that needs to be taken to begin compliance with Corrective Action Number 2." <br />AR:0214:14 -23. <br />• The Division's attorney, both at the Hearing and in the Joint Answer Brief, contended <br />Cotter could have satisfied the August 2010 Order simply by "submitting a technical <br />revision" (Joint Answer Brief at 32; AR:0206:19 -21), even though Corrective Action <br />Number 2 makes no mention of a technical revision. <br />• Board Member Paulin stated at the Hearing that the Board had not intended to require <br />Cotter to complete dewatering to 500 feet below the Steve Level by August 31, but rather <br />"implementation, you know, must be started." AR:0258:1 -7. <br />15 <br />