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III IIIIIIIIIIIII III ~~ STATE OF COLORADO MINED LAND RECLAMATION DIVISION ol~~ Department of Natural Resources ~ _ • R ~ ~+;.s " $ 1313 Sherman Sf. Room 215 H ~ 1 . Denver, CO 80203 _ ~. ' a ~• 303 6663567 '~ B ~' FA x: 303 832-6106 6 Roy Romer, Govemoi Fred R. Banta, March 14, 1990 Dnision D:renor Mr, James S. Lunan Manager Permits Peabody Coal Company 1300 South Yale Flagstaff, AZ 86001 Re: Request for Clarification of Definitions of Minor 8 Technical Revisions Dear Mr, Lunan: Thank you for your letter of February 23, 1990 I have reviewed your letter and discussed it with Mike Long. The following paragraphs should respond to the points you raised. If you're not satisfied with the response please let me know. There have not been any significant changes to the Division's interpretation of revision definitions. As you know, the definitions of minor and technical revisions are outlined in the regulations in a general manner, Given this, the determination of whether a revision is minor or technical in nature depends on numerous factors. The determination of the type of revision depends on factors such as: 1) complexity of the revision; 2) affect on the bond and or reclamation plan; 3) need for public notice; 4) affect on engineered or designed structures; and 5) whether it is a cermit stipulation. m In general, new designs of engineered structures as well as major modifications to these structures would be considered a technical re vision. A revision request that would increase the bond, significantly alter the reclamation plan (e.a. a chance in re vegetation standards) or reduce environmental monitoring would be considered a technical revision. Areauest that is somewhat complex and that could not be reviewed within the time frames set out fora minor revision would be considered a technical revision.