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William A. Bear <br />Page 5 of 9 <br />May 19, 2014 <br />c. A reference area needs to be identified, mapped, sampled and a discussion as to how <br />the area will be managed, per Rule 4.15.7(3)(b)(ii). <br />Rule 2.04.11— Fish and Wildlife Resources Information <br />22. It is stated in the discussion that current plans may include undermining the West Fork of <br />Terror Creek and that subsidence affects will be minimal on the threatened greenback <br />cutthroat trout. This summary is very limited in scope and does not adequately address the <br />requirements of Rule 2.04.11. Please include a discussion of the fish and wildlife and their <br />habitats within the Spruce Stomp lease area and where effects on such resources may <br />reasonably be expected to occur. To characterize the Greenback Cutthroat Trout <br />population and habitat, it would be helpful to include the West Fork Terror Creek 2012 Fish <br />Population and Macroinvertebrate Sampling Results as an attachment to the permit. <br />23. On page 2.04 -118, it is stated that the USFWS identified 12 species as endangered, <br />threatened, or candidate under the Endangered Species Act that may occur in Delta County. <br />Please identify the species and the 19 other sensitive species with the potential to occur in <br />the Spruce Stomp Lease as required by Rule 2.04.11(4). Has an on -site <br />threatened /endangered species survey, or block clearance for lands to be impacted been <br />undertaken? <br />Rule 2.05.3 —Operation Plan <br />24. The current BRL mining operations require gob vent boreholes (GVBs) to vent the methane <br />gas produced in the mine workings and it is assumed that GVBs will be needed for the <br />Spruce Stomp expansion area at sometime in the future. The installation of GVBs and the <br />related surface disturbance are not currently being proposed in this revision. If BRL <br />proposes to install GVBs at a later date and under a separate revision, the requirements of <br />Rules 2.05.3 and 2.05.4 will need to be addressed as they pertain to the disturbances of the <br />Spruce Stomp area. <br />25. Please provide information on BRL's proposed plans for disposal of the coal processing <br />waste, as required by Rule 2.05.3(8), that will be generated as a result of mining the <br />reserves in the PR -14 expansion area. <br />Rule 2.05.6 — Mitigation of the Impacts of Mining Operations <br />Rule 2.05.6(3) — Protection of the Hydrological Balance <br />The Division has not completed its review of the Protection of the Hydrological Balance section <br />of the permit revision application as it pertains to ground water. Comments regarding <br />protection of ground water resources will be forwarded at a later date. <br />26. Revised page 2.05 -101, first bullet, states that no mining - related surface disturbance would <br />occur within 200' of greenback cutthroat trout occupied habitat. Additionally, Rule 4.05.18 <br />prohibits any surface disturbance within 100', or greater distance if required by the Division, <br />