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Susan Burgmaier -7- July 10, 2014 <br />site threatened /endangered species survey, or block clearance for lands to be <br />impacted been undertaken? <br />BRL - The endangered, threatened and candidate species with the potential to occur on the <br />LBA are listed on page 2.04 -118. Pages 2.04 -118 and 119 are enclosed. There has not been <br />an on -site T & E survey since no disturbance on the LBA tract has been proposed or <br />approved. <br />Rule 2.05.3 - Operation Plan <br />24. DBMS - The current BRL mining operations require gob vent boreholes (GVBs) to vent <br />the methane gas produced in the mine workings and it is assumed that GVBs will be <br />needed for the Spruce Stomp expansion area at sometime in the future. The installation of <br />GVBs and the related surface disturbance are not currently being proposed in this revision. <br />If BRL proposes to install GVBs at a later date and under a separate revision, the <br />requirements of Rules 2.05.3 and 2.05.4 will need to be addressed as they pertain to the <br />disturbances of the Spruce Stomp area. <br />BRL - Comment noted. <br />25. DRMS - Please provide information on BRL's proposed plans fordisposal of the coal <br />processing waste, as required by Rule 2.05.3(8), that will be generated as a result of <br />mining the reserves in the PR -14 expansion area. <br />DBMS - No response at this time. <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. DRMS - Revised page 2.05 -101, first bullet, states that no mining- related surface <br />disturbance would occur within 200' of greenback cutthroat trout occupied habitat. <br />Additionally, Rule 4.05.18 prohibits any surface disturbance within 100', or greater <br />distance if required by the Division, of any perennial stream, requiring that the area be <br />designated a stream buffer zone and that buffer zone markers (per Rule 4.02) be installed <br />and maintained. Accordingly, the Division will require BRL to establish a stream buffer <br />zone of 200' from the normal high water line of the West Fork of Terror Creek. <br />Additionally, prior to any surface disturbance in the vicinity of the West Fork of Terror <br />Creek, BRL must install the stream buffer zone markers required by Rule 4.02. <br />BRL - Comment noted. <br />