2016-12-08_PERMIT FILE - C1981014 ‎(10)‎

• Permit No: C1981014
• IBM Index Class Name: Permit File
• Doc Date: 12/8/2016
• Section_Exhibit Name: PERMIT INTRODUCTION
• Media Type: D
• Archive: No

• expansion of the permit area, modifications to operations and monitoring
plans, and overall consolidation, updating, and organization of permit
materials. Subsequent to that meeting EFCI has proceeded with permit
development activities and supplemental reserve evaluations and long-
range planning.
Development of a comprehensive permit revision package to address long
standing CMLRD concerns resulted in delays in submitting the revision
application. It was EFCI's intent to incorporate responses to CMLRD
permit renewal adequacy comments in the comprehensive permit revision
package. This approach was based upon an understanding that timely
submittal of the permit renewal application would allow ongoing operations
under the existing permit beyond the July 30, 1989 permit expiration date.
In September, 1989, EFCI acquired information which was not previously
known to exist indicating that minable coal reserves on the Red Arrow seam
may extend well beyond the reserve limit previously defined by exploration
• drilling in the 2-North area. EFCI is proceeding with further exploration
to confirm this information. Assuming that the information is valid, EFCI
would not want to cut-off access to these additional reserves by
proceeding with the previously planned retreat from this area.
Elimination of retreat mining for the 2-North area cut-off the six (6)
months of Red Arrow reserves EFCI had designated to meet production and
blending requirements during the interval required for permit
renewal/revision review and approval.
As a consequence of mine plan changes resulting from the desire to
maintain access to potential additional Red Arrow reserves, EFCI was faced
with an immediate need for extension of existing permit boundaries in the
2-North area to allow continued mine advance. The alternatives would be
to move the entire 2-North equipment section to another area, or to shut
down 2-North temporarily and increase production from the Jack O'Lantern
seam to continue to meet customer requirements. Increased production from
the Jack O'Lantern seam has a multiplicative effect on mine life with each
• additional month of Jack O'Lantern production reducing remaining mine life
by two (2) months due to blending considerations. Both alternatives would
result in significant operational and economic impacts.
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