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New 3809 Requirements Relating to Financial Guarantees, Inspection, Enforcement, and Appeals

Michael S. Giannotto, Valerie E. Ross, Review and Analysis of the New BLM Surface Management (3809) Regulations (2001)

1.No financial guarantees are required for operations that qualify as casual use.

2.Financial guarantees are now required for all new notice-level activities.

a.This is a change from the pre-existing rules.

3.Financial guarantees are now mandated all plan-level activities (under the pre-existing rules, financial guarantees were discretionary, although, in practice, they were required for all plans of operations). The requirements for such guarantees have changed, however.