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• Along with noted changes in mining and reclamation plans, EFCI has also <br />reviewed, updated and organized the entire Southfield permit document in <br />order to address longstanding MLRD concerns. The resulting comprehensive <br />document can be utilized both as an overall guideline for ongoing and <br />future operations and as a tool to ensure continued compliance with all <br />applicable regulatory requirements. <br />Both the original Southfield permit and this comprehensive permit revision <br />application are based upon all available geologic data, information on <br />environmental baseline conditions, available mining and reclamation <br />technology, capabilities and limitation of existing equipment, EFCI's <br />operating experience, and applicable State and Federal regulations. <br />At the time that EFCI purchased and began operating the Southfield Mine, <br />it's objectives were to maintain ongoing production, improve overall coal <br />recovery, develop operationally feasible short and long range mine plans <br />• and maintain compliance with all applicable regulatory requirements. EFCI <br />has effectively attained these objectives by maintaining ongoing <br />production which is currently at a level of 550,000 clean tons of coal per <br />year. Coal recovery in the preparation plant has been increased from 557 <br />to approximately 65%. Short and long range plans have been developed, <br />forming the basis for this permit revision application. EFCI has also <br />maintained an effective record of ongoing compliance with applicable <br />regulations and cooperation with regulatory authorities. <br />This permit revision application addresses the following specific changes <br />to mining and operation plans. These changes are necessary to allow EFCI <br />to continue to meet its operational and compliance objectives; <br />o Expansion of the permit area to encompass reserves required <br />for future operations <br /> o Reduction of permanent coal refuse stockpile cover <br />. requirements consistent with planned post-mining land uses <br />2.05-2 <br />