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Enclosure 1 Item 1 43 CFR 3482 regulations (c) (1) through (c) (7) detail certain Mineral Leasing Act (MLA) requirements in regard to the resource recovery and protection plan that must be a part of a mine permit application package. Except for the following inadequacies, the Seneca II-W Mine Permit Application seems to adequately address these requirements based on our review and analysis. A) 43 CFR 3482.1 (c) (3) (iii) "An estimate of the coal reserve ase, mina a reserve ase, and recoverable coal reserves for each Federal lease included in the resource recovery and protection plan" (permit application). The coal tonnage values are to be calculated based on the 43 CFR 3480.0-5 definitions. For this application, the coal reserve base tonnages must include all defined coal seams above an overburden depth of one hundred (100) feet over the entire area of each lease. The same one hundred (100) foot sublessee consideration applies to the calculation of the minable reserve base and recoverable coal reserve tonnages within the designated minable areas. An additional map should be provided that shows the area(s) corresponding to the coal reserve base lease tonnages. Based on the designated areas to be mined as drawn on Map 12-1, our geologists and mining engineers calculated the Wadge recoverable coal tonnage to be 9,389,600. An average coal thickness of twelve (12) feet, a coal density factor of 1,770 tons/acre-foot, and a recovery factor of 95 percent were used in this calculation. The application gives a life-of-mine estimated tonnage of 8,369,700 which is 1,019,900 tons (10.9 percent) less than our estimate. The applicant must provide backup calculations of their recoverable coal reserve tonnages, minable reserve base tonnages, and coal reserve base tonnages by lease. B.) 43 CFR 3482.1 (c) (4) (i) (D) "A plan map of the area to be mine sowing t e o owing - coal outcrop." Three exhibit maps labeled 6-1, 6-4, and 12-1 provide the location of what is described as the Wadge coal seam outcrop or cropline. These maps are in agreement. However, the exhibit geologic cross-sections labeled 6-GX-5 and 6-GX-7 are not in agreement ~ for the bounded outcrop shown within the mining area along the gulch that empties into sediment pond #006. The horizontal distances transected on these cross-sections between outcrops are signficantly less than that shown on the aforementioned plan maps. The limits of mining shown for the Wadge on the cross-sections approximate the lines referred to as outcrop or cropline on the plan maps. Further, the exhibit labeled 12-5R3 range diagram/cross-section depicts stripping to within fifteen to twenty feet of overburden along this drainage.