2015-10-08_REVISION - C1981041 ‎(12)‎

• Permit No: C1981041
• IBM Index Class Name: Revision
• Doc Date: 10/8/2015
• Doc Name: Proposed Decision and Findings of Compliance
• From: DRMS
• To: Snowcap Coal Company, Inc
• Type & Sequence: SL8
• Email Name: BFB
• Email Name: DIH
• Media Type: D
• Archive: No

Attachment 7
J. E. STOVER & ASSOCIATES, INC.
2352 NORTH 7TH STREEET, UNIT 8
GRAND JUNCTION, COLORADO 81501
PHONE: [phone], FAX: [phone]
MINE ENGINEERING
MINE RECLAMATION
October 21, 2013
Mike Boulay
Division of Reclamation, Mining & Safety
1313 Sherman St, Room 215
Denver, CO 80203
Re: Snowcap Coal Company
Bond Release Written Objection
Permit C-1981-041
Dear Mr. Boulay:
CML ENGINEERING
CONST. MANAGEMENT
Mr. Rudolf Fontanari, Jr. filed a written objection to Snowcap Coal Company's bond release application
SL -8 by a letter to the Division of Reclamation Mining and Safety (DRMS) dated October 7, 2013. Mr.
Fontanari believes he is likely to be adversely affected by the bond release. A meeting was held at the
mine site with Mr. Fontanari on September 18, 2013. Mr. Fontanari explained most of his concerns
during the meeting to Mike Boulay with DRMS and Jim Stover and Tonya Hammond representing
Snowcap Coal Company (SCC). On behalf of SCC following are its comments regarding Mr. Fontanari's
objections.
1. Mr. Fontanari alleges subsidence features have been apparent on the surface and continue to
develop periodically.
SCC - Surface subsidence is an accepted impact of coal mining. In some cases subsidence
features such as fractured cliff faces and irregular surface contours can be apparent on the
surface long after mining is complete. Most subsidence occurs shortly after mining is complete
and the remaining residual subsidence occurs within two to three years after mining. The short
timeframe for the effects of subsidence is confirmed by a DRMS policy memorandum dated April
13, 1987 regarding release of liability of areas overlying underground opal mine workings. The
policy memorandum states that for areas of extraction the liability period shall be a minimum of
three years after mining. The underlying point of this policy memorandum is that most, if not
all, subsidence occurs within three years after mining.
2. Mr. Fontanari alleges subsidence features cross perceived permitted boundaries, indicating a
potential misidentification of extracted resources.
SCC - During the onsite meeting, Mr. Fontanari explained that he believes a prior operator
mined some coal which it did not have the right to mine. Mr. Fontanari has expressed this
7-1