2016-12-09_REVISION - C1996083 (4)

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COF+�EkVnTl�h1 F?+iTER Western Slope Conservation Center 204 Poplar Ave, Paonia, CO 81428 Ginny Brannon, Director Colorado Division of Reclamation Mining and Safety 1313 Sherman St., Room 215 Denver, CO 80203 Ginny.brannongstate.co.us Re: Bowie No. 2 Coal Mine (Permit No. C-1996-083), Application for Technical Revision No. 110 (TR -110) and Proposal for Installation of Coal Gasification Plant within the Permit Area Dear Director Brannon: Pursuant to the November 30, 2016 notice published in the Delta County Independent, the Western Slope Conservation Center hereby requests a public hearing or series of public hearings on the above -identified application and proposal on behalf of our members and the citizens of Delta County. From the little information available, we understand that Bowie's proposal is to construct a coal gasification facility on its Bowie No. 2 coal mine site. The company's application reportedly states that the facility, known as a "DAXIOM Plant," will be used to convert coal mine waste to synthetic gas, which is then used to generate either electrical power or diesel/fuel oil. There is a plethora of questions that arise from this proposal, with impacts spanning from economic to environmental, that our members and the public must address to more fully evaluate the potential beneficial and detrimental impacts of the proposal. Not the least of these concerns is the technological feasibility of the proposed operation. The proposed permit revision has significant implications for air quality, water quality, waste management, and mine reclamation, and because of the location, may affect Bureau of Land Management (BLM) and U.S. Forest Service (USFS) lands. Due to these concerns, it is prudent that the Colorado Division of Reclamation Mining and Safety (DRMS) seek advice and utilize the expertise of additional agencies, including the U.S. Office of Surface Mining Reclamation and Enforcement (OSMRE), the BLM, the USFS, the Colorado Air Pollution Control Division (APCD), the Colorado Water Quality Control Division, the Colorado Hazardous Materials and Waste Division, and the Environmental Protection Agency (EPA). A copy of this letter is being forwarded to these agencies. We also question whether the subject application for Technical Revision No. 110 qualifies more appropriately as a Permit Revision, pursuant to Colorado Mined Land Reclamation Board Coal Mining Regulations (revised September 14, 2005; hereinafter referred to as "Colorado coal mining regulations"), Section 2.8.04(6)(b)(ii). This application appears to be potentially more than an "incidental boundary permit revision" as referenced in Section 2.08.4(2) or a "minor permit modification" as referenced in Section 1.04(136) of the Colorado coal mining regulations. Public hearings will permit exploring why this application is more appropriately deemed a Permit Revision due to what a dearth of information indicates to be significant alterations in the surface coal mining and/or reclamation operations that were described in the original permit application.