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authority to use additional information sources, including
inspectors and auditors, to improve the data base.

Evaluate Permit Number and MSHA Identification Association:
The Clearinghouse staff will continue to develop and improve
information that associates permit numbers with MSHA
identification aumbers. The data is fundamental to matching
owners and controllers with violators.
Improve Data Entry Standards: Training of regulatory authority
staff will continue to assure that all new permit application
information is entered into AVS correctly.

Correct Data Errors on an On-going Basis: Clearinghouse staff
and regulatory authority personnel standard research activities
identify data errors or inconsistencies that will continue to
be corrected on an on-going basis.

Industry "Fingerprint" Reports: Efforts to work directly with industry to improve information contained in AVS for each permit and permit application will continue. The on-going activity encourages each company to correct errors and/or provide missing information.

Question:

How many FTEs are included in the Fiscal Year 1989 request for the Applicant Violator System clearinghouse? How has OSM determined that this number is adequate?

Answer:

The AVS Clearinghouse will continue to operate with 9 FTES throughout Fiscal Year 1989. OSMRE believes that no change in the FTE level is necessary because of the use of contractor resources to conduct many of the Clearinghouse functions. The use of contractors better enables the Clearinghouse to manage its staff resources to meet the current and projected workload. There are currently 17 contractor personnel in addition to the permanent OSM staff in the Clearinghouse.

Question:

How will OSM assess the quality and integrity of the data being input into the system by the State regulatory agencies?

Answer:

All new and revised AVS data are entered into the system by the
regulatory authorities through their local AVS terminals. Each
AVS operator has been fully trained in the use of the system
and receives regular updates to keep them current. The local
AVS terminal has resident software to help assure the accuracy
and completeness of each system transaction. Additional
quality assurance 18 provided when these data are "uploaded" to
the mainframe computer that operates avs. Finally, OSM's
oversight procedures include a review of the regulatory
authority's timeliness and accuracy of data entry.

Coal Data Management Information System

Question:

OSM is also proposing to make a reduction of $1,200,000 in
administrative support as a result of revising its level of
effort in the area of the Coal Data Management Information
System (CDMIS). Explain in detail what activities OSM will be
deferring in Fiscal Year 1989 to accomplish this goal.
The Coal Data Management Information System (CDMIS) is
comprised of five subsystems.

Answer:

o Decentralized Enforcement and Centralized Accounting (DECA)

Subsystem. DECA will automate the inspection and scheduling functions and all attendant activities.

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Grants and Reclamation Subsystem. This subsystem will
support OSMRE functions involving Title IV and Title V
grants for States as well as Federal reclamation activities.

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AML Fees Subsystem (FEEBACS). This system will keep track of AML fees due, paid and accounted for.

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Integration of AVS Subsystem. This activity will involve integrating the current permit management process (Applicant Violator System) into CDMIS.

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Bonds Management Subsystem. This subsystem will manage all bonding activities associated with permits that have been issued.

Original CDMIS development plans called for the first two of the subsystems to be implemented in FY-89. The DECA subsystem is currently under development with FY-88 funds and will be implemented in FY-89.

The proposed reduction in funding means that the Grants and Reclamation Subsystem will be delayed and not be developed until FY-90.

Question:

Discuss the cost/benefit analysis that OSM is undertaking on CDMIS and what it will examine. When does OSM estimate that this analysis will be completed?

Answer:

OSMRE staff has completed an initial cost/benefit analysis of
CDMIS. The analysis evaluated the existing systems that CDMIS
will replace along with the reasonable alternatives to CDMIS
development. An independent contractor is being used to expand
the analysis and to ensure its objectivity. The contractor has
the experience and specialized expertise necessary to conduct a
comprehensive cost/benefit analysis. The project plan calls
for the contractor to independently expand the initial analysis
to fully evaluate the costs and benefits of the project
alternatives in order to determine the feasibility of CDMIS.

The contractor will begin work around the first of April, 1988.
The project plan calls for deliverables to be staggered over

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the ensuing four months. It is expected that the final product will be delivered sometime in mid-summer (July - Aug).

Question:

How will OSM solve the problem of lack of standardization of
State data in incorporating this information into CDMIS?

Answer:

After the CDMIS subsystems are all fully developed, the final step will be to integrate State data into the CDMIS data base. This action 18 targeted for FY-92 and FY-93. To the greatest extent possible, existing automated State data systems will be utilized by uploading certain State data into CDMIS.

It does aot appear feasible or necessary to load State data
into a central data base. Rather integration of State data on
an as needed basis is the goal. In the case of those States
that do not have automated systems, OSMRE will develop software
which the States can use to build their own systems which will
interface with CDMIS.

Base Adjustments

Question:

Discuss the base adjustments OSM is making in Fiscal Year 1989.

Answer:

The majority of the base adjustments result in marginal
increases in most program areas. Base adjustments include
increases for such items as office space rental, workers as
compensation, working capital fund and Federal
Telecommunications System (FTS). For example, space costs for
OSMRE have increased at a higher than expected rate beginning
in Fiscal Year 1988, due to rate increases. The OSMRE
decentralization had an impact on these costs because most
Field Office space is commercially leased. In addition, the
adjustment for FTS reflects a 4.3 percent rate increase in
June 1988 and additional lines anticipated in 1989. An
adjustment between the Fiscal Year 1989 base costs of
Interior's Fish and Wildlife Service (FWS) and OSMRE will be
sought to adjust for FWS charges for OSMRE FTS line costs.
The net amount of base adjustments in the Regulation and
Technology appropriation is $201,000. A net amount of $110,000
is included in the Abandoned Mine Reclamation Fund
appropriation.

Question:

What impact will these have on the operation of the program?

Answer:

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The proposed base adjustments will not have any negative
effects on program operations.

Federal Employee Retirement System

OSM has re-estimated the cost in Fiscal Year 1988 for the federal contribution to the Federal Employee Retirement System (FERS).

Question:

What will OSM do with the $1,381,000 which will not be
necessary for FERS in Fiscal Year 1988?

Answer:

Although the Fiscal Year 1988 enacted appropriation shows a savings of $1,381,000, actual FERS costs to date indicate the savings to be approximately $1,181,000. The $1,181,000 will bs used to help offset the January pay raise for which no supplemental appropriation was proposed and rental space costs. $681,000 will be used to cover the pay raise and $500,000 to offset increases in rental space. The $681,000 represents a slight increase over the amount ($623,000) included in the Fiscal Year 1989 budget document due to revised estimates.

State Regulatory Program Grants

Question:

The justification on page 27 states that the regulatory grant estimates which total to $41,910,000 will undergo continued review. When will OSM make a final decision on the Fiscal Year 1989 grants?

Answer:

In accordance with OSMRE procedures, 18 months prior to the beginning of the fiscal year, the States are requested to provide estimates for that fiscal year. Those estimates, as reviewed by our Field Offices, form the basis for our budget estimates. Six months prior to the beginning of the fiscal year, States are asked to update their estimates. The final allocations are based on our reviews of the estimates, the States' historical obligation patterns, the States' updates and the actual funds appropriated by Congress.

Question:

How much would OSM expect the adjustments to deviate from the estimates on page 27 of the justification?

Answer:

Based on recent experience, the funds appropriated by Congress generally match the budget estimates, and therefore required adjustments are minimal.

Question:

What major program changes did OSM consider in Fiscal Year
1987?

Answer:

In FY 87 forty State program amendments were acted upon by OSMRE with final rules published in the Federal Register. Examples of major actions included in the group were regulatory reform amendment proposals from Kansas, Virginia, Wyoming and Ohio to conform to Federal rule changes promulgated in 1983. Illinois adopted revised revegetation regulations and Kentucky established a bond pool. A significant number of States

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responded to new requirements to regulate off-site coal
preparation plants.

An additional 45 proposed State program revisions were la
various stages of review at the close of FY 87.

Question:

What major program changes does OSM expect to review in Fiscal
Years 1988 and 1989?

Answer:

During FY 88 approximately 25 amendments had been completed by
mid-year. OSMRE projects that an additional 25 to 30
amendments will become final by year end. These will include
amendments concerning the North Dakota bonding regulations,
Virginia remining regulations and Kentucky reclamation
requirements. Regulatory reform amendments are anticipated
from Alabama, Arkansas, Colorado, Louisiana, Maryland,
Missouri, Oklahoma, Texas and Wyoming.

OSMRE anticipates a significant workload associated with
processing amendments submitted by the States to amend their
permanent regulatory programs in FY 89. FY 89 amendments will
include regulatory reform amendments from Alaska, Indiana,
Iowa, Maryland, Missouri, Montana, New Mexico, North Dakota,
Pennsylvania and Utah. OSMRE plans publication of revised
federal regulations including topics such as ownership and
control, coal exploration, permit conditioning, revegetation,
valid existing rights, roads, prime farmlands and exemptions
for coal extraction incidental to the extraction of other
minerals during calendar year 1988. It is expected that some
State program changes related to these Federal revisions will
occur in FY 89. The total number of amendments that will be
processed in FY 89 is expected to increase to between 60 and
75.

Question:

What do these program changes involve?

Answer:

Program changes are discussed in the answer to the previous question.

State Inspectors

On page 25 of the justification OSM has included a chart
outlining the number of State inspectors.

Question:

How many inspectors do each of the state programs require?

Answer:

Each State regulatory authority must maintain sufficient inspectors to carry out the State's inspection and enforcement provisions. Each of the 24 States with approved programs have developed required staffing levels after taking into consideration unique State conditions such as the number, size, and location of surface coal mining and reclamation operations within the State, coupled with the inspection frequency requirements. Based upon those criteria, staffing levels were

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