2014-09-09_REVISION - C1996083 ‎(3)‎

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 9/9/2014
• Doc Name: Adequacy Response #2
• From: J.E. Stover & Associates, Inc
• To: DRMS
• Type & Sequence: PR14
• Email Name: SLB
• Email Name: DIH
• Media Type: D
• Archive: No

Susan Burgmaier -4- September 2, 2014
disturbances can be approved. As noted in Item 19, above, the Division will place a stipulation
on the approval of PR -14 to require baseline vegetation data prior to any disturbance in the
Spruce Stomp lease area.
BRL - As soon as the lease is issued, BRL needs to permit a road that just barely clips the edge of
the Spruce Stomp expansion area. The road will allow safer access to the B17 GVBs. BRL
requests the stipulation be worded so DRMS can approve certain limited disturbance within the
Spruce Stomp expansion area.
21. Issue resolved; no response to the Division's comment was required from BRL.
Rule 2.04.11— Fish and Wildlife Resources Information
22. Issue resolved; BRL provided the requested discussion as a new Exhibit in Tab 23 of
Volume 1116.
23. The Division anticipates that future operations will involve disturbances in the Spruce
Stomp expansion area (see Item 20, above). Please take note that a threatened /endangered
species survey or block clearance will need to be submitted and approved before any future
disturbances can be approved. As such, a stipulation will be placed on the approval of PR -14
prohibiting any surface disturbance in the Spruce Stomp lease area until the required survey or
clearance has been submitted to and approved by the Division.
BRL - Comment noted.
Rule 2.05.3 — Operation Plan
24. Issue resolved; no response to the Division's comment was required from BRL.
25. BRL did not provide a response to this issue: Please provide information on BRUs
proposed plans for disposal of the coal processing waste, as required by Rule 2.05.3(8), that
will be generated as a result of mining the reserves in the PR -14 expansion area.
BRL - The prospective land purchase for a new coal mine waste disposal area has not closed.
Rule 2.05.6 — Mitigation of the Impacts of Mining Operations
Rule 2.05.6(3) — Protection of the Hydrological Balance
26. Issue resolved; no response to the Division's comment was required from BRL.
27. The Division asked BRL to update Maps 09, 15 -1, 15 -2, 15 -3, and 15 -4 to include the
designated stream buffer zones required by Rule 4.05.18 for all perennial streams and
intermittent streams or ephemeral streams draining an area greater than one square mile
within the permit area boundary. BRL indicated that depiction of the stream buffer zones is not
required by the rules. Although not required by a specific rule, Rule 2.10.3(1)(1) allows the
Division to require "other relevant information... for good cause shown." The Division believes
that showing the stream buffer zones on the maps will ensure that stream buffer zones are
considered in any future permitting actions for surface disturbance in the vicinity of the