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Oxbow believes that the extraction of the coal mine methane could benefit the future mining of <br />the federal coal resource. Bowie encounter an increasing amount of methane as the mine <br />advanced, which reduced productivity and increased the volume of air requred to dilute the <br />methane to safe levels. Draining methane from the mine will reduce the amount of methane that <br />will be encounterd, if mining was to resume. <br />If a future operator was to open the mine, ventilating all of the methane to safe levels would be <br />required. Replacing the seal remotely through one of the drill hole is one possible approach to <br />ventilating the mine. Remote seal pumping is technically feasible and has been successfully <br />used in the coal industry. Reducing the amount of methane trapped in the mine will also make <br />the future openning of the mine easier and less expensive. <br />I would also like to bring to your attention the Bureau of Land Management Waste Mine <br />Methane Policy, IM 2017-037. (attached) The purpose of this policy is stated as "establishes <br />national policies and processes to foster voluntary activities by operators to capture waste mine <br />methane from underground coal mines". <br />The Policy/Action is stated as "waste mine methane (WMM) is defined as methane released as a <br />direct consequence of underground mining before, during and after mining of the coal". "The <br />BLM will implement this policy through two main mechanisms: authorizing operators to capture <br />WMM, and woring with operators to encourage such capture and other waste reduction actions." <br />I would urge you to review this Methane Policy and to work with both Bowie and Oxbow for the <br />approval of this Technical Revision. <br />I would also like to bring to your attention Colorado Senate Bill 13-252 (SB 252). SB 252 was <br />signed in 2013 increasing the Rural Renewable Energy Standard to 25% by 2020. It also <br />expands the definition of "eligible energy resources" to include coal mine methane. The purpose <br />to this technical revision is to remotely remove a seal in the mine. Oxbow would then evaluate <br />the potential of using this methane as a Renewable Resource. <br />I would be happy to meet with you and your staff in your office to discuss this TR in further <br />detail if you need addition information. I encourage you to consider this information for a <br />possible revision to your letter to the Colorado Division of Reclamation Mining and Safety. <br />Sincerely, <br />f <br />Michael Ludlow <br />President <br />Oxbow Mining, LLC <br />P.O. Box 535 <br />Somerset, Colorado 81434 <br />CC via email <br />Claton Wein, cla3lon.wein2state.co.us <br />Bill Bear, BBearkbowieresources.com <br />0 Page 2 <br />