2016-12-13_REVISION - C1996083 (125)

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planning, cost, and feasibility of removing the plant, cleaning up whatever waste may be generated by the plant (e.g., ash), and restoring the area to pre -mining conditions. The addition of such a major industrial development would appear to significantly change Bowie's operations and reclamation obligations, indicating that a Permit Revision is necessary. Even putting aside whether or not DRMS concludes that the proposal, as it stands, would pose significant alterations to Bowie's mining and reclamation plans, DRMS must conclude that there is insufficient information provided to determine whether a Technical Revision is, in fact, appropriate. Bowie appears to have provided few specific details to DRMS regarding what the "DAXIOM Plant" will actually do, what impacts such a facility will have on the permit area, what amounts and types of waste may be generated by such an operation and how such waste will be handled, what costs are involved with the plant, what unique reclamation requirements are created by the construction of such a plant, and whether construction and operation of the plant will fully comply with performance standards set forth under Rule 4 of the Colorado coal mining regulations. The 1 -page "Reclamation Estimate" included with the application is therefore largely baseless, and is unlikely to accurately reflect what reclamation may be necessary at what cost. It is noteworthy that we can find no information on the World Wide Web related to a "DAXIOM Plant" (and almost no information about the rather mysterious Bahamian company that will supply the Plant) and Bowie's application simply describes the plant as a "patent pending process for the recovery of energy from waste materials." Although general schematics and concepts are provided in the revision application, no specific information is provided, including any blueprints of the facility or other construction and operation diagrams. All appearances are that Bowie is applying to DRMS to construct and operate a purely experimental, un -proven surface mining activity. Approving an experimental, "patent pending" plant that converts coal and mine waste to gas and ultimately to diesel fuel and fuel oil cannot represent a "minor" permit modification. With such significant uncertainty, risk, and unknowns, DRMS's proposal to approve the revision as Technical Revision is not appropriate. Given the lack of data about the technology from anyone but the proponent, DRMS cannot simply take at face value Bowie's suggestion that the "DAXIOM is a state of the art gasification process ... [that] generates virtually no pollution," particularly when DAXIOM's information sheet submitted with the application discloses a long list of air pollutants that may be emitted by the facility. See TR -110 Application, Ex. 25, Daxiom Information Sheet at 5. Information in the application also raises questions about what the DAXIOM Plant could ultimately be used for. The materials describing the DAXIOM plant state: "Processing of all organic energy sources is easy, e.g. household waste, wood, tires, biomass, sludge, hospital and veterinary waste, lignite coal, impure coal." See TR -110 Application, Ex. 25, Daxiom Information Sheet at 2. This raises the possibility, however remote, that once the plant is built, it could be used not only to burn coal waste, but also as a garbage, tire and/or medical waste incinerator, uses which could have additional environmental impacts at the site and in nearby communities. Further, Bowie's application may indicate that the company intends to cease permanently coal mining at the site and replace its mining operations with the proposed coal gasification