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permit boundary modifications noted in the comment above. The Permit Area was noted in <br />TR13-83 (both pages 2.01-4 and 2.05-3) as 21,447 acres. With the addition of 160 acres for <br />PR14-10 in Sections 12 and 13 (TSN, R86W), the total Permit Area acreage should be 22,607. <br />d. Division's response: Upon further review, the large difference in permit acreage the Division <br />has been recording and what Twentymile Coal has determined seems to have originated with <br />Permit Renewal Application No. 3 (RN3), Permit Revision No. 5 (PR5) and subsequent <br />revisions. It appears the Division requested the permittee to clarify the permit acreage with <br />RN3 and there was a decision made on what the permit area should be. However, I cannot <br />determine for certain what the final decision was based on the information in the Division's file <br />for RN3. But, PR5 and RN3 were under review at about the same time period and PR5 was <br />approved two months after RN3 was approved. When PR5 was approved, permit page 2.01-4 <br />was updated with a revised permit area of 23,040.9 acres. Technical Revision No. 33 (TR33) <br />was submitted during the review of PR5 and was approved prior to PR5 and added 7.2 acres to <br />the permit area. The date on revised page 2.01-4 is prior to the date TR33 was submitted. <br />TR33 did not update page 2.01-4 so it is likely the 23,040.9 acres from PR5 does not include the <br />7.2 acre addition from TR33. By adding the 7.2 acres, the total permit area should have been <br />23,048.1 acres with the approval of PR5. The Division's decision form does not appear to have <br />been updated with the correct permit area when RN3/PR5 was approved. PR6 requested to <br />increase the permit area by 560 acres. This revision was approved but it does not appear the <br />Division's decision form accounted for the increase in acreage. With the approval with PR6, <br />the permit area should have been 23,608.1 acres (23,048.1 + 560 acres). Then, TR51 reduced <br />the permit acreage by 1,320 acres. During the review of TR51, the permittee submitted MR205 <br />which should not have changed the permit acreage. When the Division approved MR205, the <br />decision form indicated a permit area that was 1,320 acres less than the previously approved <br />permit area. Subsequently the Division approved TR51 and reduced the permit area again by <br />1,320 acres. Given this, it appears the 1,320 acres was inadvertently reduced twice from the <br />Division's records. When TR51 was approved, the permit acreage should have been 22,288.1 <br />acres. Subsequently, with TR82, the Division approved a 160 acre increase in the permit <br />boundary yielding a permit area of 22,448.1 acres (22,288.1 + 160 acres). PR10 requests an <br />approval of a 160 acre increase in the permit area. By adding 160 acres to 22,448.1 acres, the <br />total permit area should be about 22,608.1 acres. PR10 indicates the permit area should be <br />22,607 acres. The 1.1 difference in acreage is likely due to a rounding error. The Division will <br />fix the discrepancy in our records. <br />Also, the Permit Renewal No. 6 (RN6) application listed the mineral and surface ownership <br />acreage by ownership (Federal, State and Private acreage). The table below depicts this <br />information. <br />RN6 <br />Application <br />Federal <br />State <br />Private <br />Private <br />PR10+ <br />TOTAL <br />Surface <br />6070 <br />7613 <br />8767 <br />160 <br />22610 <br />Mineral <br />8478 <br />7758 <br />6214 <br />160 <br />22610 <br />There is a discrepancy of three acres between what TC indicates the permit area should be and <br />what the sum of the ownership acres yields. Please review the ownership acreage (both surface <br />and mineral) and update the information so that the total ownership acreage equals the 22,607 <br />acre permit area. <br />e. TC's response: As a practical matter, when dealing with the Permit Area and ownership <br />acreages, because the numbers are relatively large, TC has always rounded to the nearest whole <br />acre, a practice which has been accepted by the Division. The referenced difference between <br />the ownership acreage provided in the Permit Renewal application and the cumulative acreage <br />carried forward for the Permit Area reflects this rounding convention, is negligible given its <br />relative magnitude (3 acres/22607 acres = 0.000133, or 0.0132%), and does not require <br />