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<br /> <br />December 8, 2016 <br /> <br />Ginny Brannon, Director <br />Colorado Division of Reclamation Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Ginny.brannon@state.co.us <br /> <br />Re: Comments on Bowie No. 2 Coal Mine (Permit No. C-1996-083), Technical Revision No. 110 (TR- <br />110) <br /> <br />Dear Director Brannon: <br /> <br />On behalf of The Wilderness Society please accept and fully consider these comments regarding <br />Technical Revision No. 110 submitted by J.E. Stover & Associates, Inc. on behalf of Bowie Resources, LLC, <br />Bowie No. 2 Mine (“Bowie”). The technical revision requests the Division of Reclamation Mining and <br />Safety (“Division”) revise Bowie’s existing permit to allow for the construction of a “DAXIOM” coal <br />gasification plant. <br /> <br />The Wilderness Society (“TWS”) is America’s leading public lands conservation organization. Since 1935, <br />TWS has been dedicated to protecting America’s wild places for current and future generations. We are <br />also committed to the principal that, where coal development occurs on our public lands, it is carried <br />out in a manner that recognizes that it is one, exclusive use of the public lands that must be balanced <br />with other multiple uses and that conservation should be considered on equal ground with any coal <br />development. <br /> <br />TWS believes that the information provided in the application submitted by Bowie is insufficient for the <br />Division to make an informed decision regarding the request for a technical revision. Additionally, given <br />the surface and mineral interests that make up the Bowie No. 2 Mine and the potential implications for <br />our federal lands, we encourage the Division to confer with the Bureau of Land Management (BLM) <br />regarding the pending application. Specific comments follow. <br /> <br />1. Federal surface and subsurface mineral interests necessitate consultation with the BLM. <br /> <br />According to the application, the Bowie No. 2 Mine consists of roughly 11,000 acres of land with mixed <br />private and federal surface and subsurface acreage. From the application, it appears that surface <br />acreage is split roughly 50-50, while federal acreage accounts for over 80% of the subsurface estate. The <br />mine itself is made up of multiple leases, including two federal leases: COC-37210 (5,274 acres) and <br />COC-61209 (4,196 acres). Because of the majority federal interest in the mine’s surface and subsurface <br />estate, as well as the presence of the two existing federal coal leases, any action proposed in the <br />technical revision has the potential to impact federal lands and potentially conflict with the existing <br />federal lease terms. Additionally, the proposed action by Bowie could very well necessitate a revision of