I have read through the initial draft of the Financial Assurance Rules and feel that these rules need significant modification. Rather than submitting specific comments and providing the state with proposed language I would like to suggest the workgroup consider adopting another state's financial assurance rules and modifying them to fit the statute.  I understand that the state of Montana has thorough and up to date financial assurance requirements, and would suggest we look at those as a potential model.  With such a short period to work on this I think there is a danger of running out of time and ending up with less than adequate financial assurance provisions.  I would also like to ask that Stephen Hoffman of the US EPA be asked for recommendations regarding this matter, as I understand that this is one of his specialties.

Todd L. Warner
Keweenaw Bay Indian Community
Natural Resources Department
HCR01 Box 120, L'anse, Michigan 49946
(906) 524-5757 Extn. 18
Fax   524-5758