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significant, and speculative new industrial facility before fully consulting these agencies and <br />seeking their expertise, scrutiny, and recommendations. <br />The undersigned may be adversely affected by a decision approving the proposed <br />technical revision because construction of a coal gasification plant as sought in the application <br />for Technical Revision No. 110 has potential to adversely impact air, water, and other <br />environmental values that the groups' members use and enjoy. See Colorado Mined Land <br />Reclamation Board Coal Mining Regulations (revised September 14, 2005) (hereafter "Colorado <br />coal mining regulations") Section 2.8.04(6)(b)(ii). <br />1. The Proposed Revision Does Not Qualify as a Technical Revision. <br />We are concerned that DRMS has proposed to approve Technical Revision No. 110 when <br />in fact the proposed permit revision would qualify as a Permit Revision and not a Technical <br />Revision. <br />Colorado coal mining regulations at Section 2.08.4(2) state that a Technical Revision of a <br />permit is allowed only where there is an "incidental permit boundary revisio[n]," where <br />"required by an order issued under 2.08.3(3)," or for "minor permit modifications" meeting the <br />criteria of Colorado coal mining regulations at Section 1.04(136). The criteria set forth under <br />Section 1.04(136) provide that a technical revision of a permit is only allowed where a change <br />will "not cause a significant alteration in the operator's reclamation plan." <br />On the other hand, Colorado coal mining regulations at Section 2.08.4(1)(a) state that a <br />Permit Revision is required for "significant alterations in the surface coal mining or reclamation <br />operations described in the original permit application." <br />Here, the proposed revision would certainly cause a significant alteration in the <br />operator's mining or reclamation plan, and thus would qualify as a Permit Revision under <br />Colorado coal mining regulations. According to the application Bowie Resources, LLC, <br />submitted, the proposed revision would authorize the recovery of waste coal and other mine <br />waste and the construction of a "DAXIOM Plant," which will apparently convert waste coal and <br />other mine waste into synthetic gas, which will in turn be used to generate diesel fuel or fuel oil. <br />Aside from the fact that little specific information is provided in Bowie's revision application <br />describing in detail what the "DAXIOM Plant" will actually be on site, all information in the <br />application thus far indicates that a massive and significantly different new coal recovery and <br />processing operation will be constructed within the permit area. In many respects, what Bowie <br />is proposing appears akin to an oil refinery, which also processes diesel fuel or fuel oil. <br />This represents a significant alteration in the surface coal mining operations. The <br />construction of a "DAXIOM Plant" is unlike anything else currently constructed on the site of <br />Bowie's permit area — indeed, it is as far as we know, a facility without precedent in recent <br />decades on any mine in the state — and Bowie's proposal to process coal mine waste, which we <br />presume includes waste coal, is unlike any mining operations that have recently occurred within <br />the permit area. What's more, with the construction of the "DAXIOM Plant," it would appear <br />that Bowie's reclamation plan would be significantly altered as it would have to account for the <br />2 <br />