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If the plan maps have been incorrectly labeled, the proper <br />terminology should be given in a revised narrative with <br />reference to the appropriate maps. A justification for leaving <br />the coal shown on the two geologic cross-sections would then be <br />required as this would not be in the interest of Maximum <br />Economic Recovery (MER). It would be our contention that the <br />Wadge coal can be mined much closer to the gulch if the coal <br />quality is favorable. <br />In addition, the line referred to as Wadge outcrop (cropline) <br />that somewhat parallels the top of the ridge, does not appear to <br />be the true outcrop. Based on a Wadge overburden map <br />constructed by our geologists, the true outcrop should be from <br />one hundred (100) to two hundred (200) feet further up the <br />hillside. It would seem that the lines shown on the application <br />maps may better be termed "Wadge cropline recovery". This would <br />reflect low quality unrecovered coal to be left between the <br />aforementioned recovery line and the true cropline. If this is <br />the case, the applicant needs to provide written clarification <br />and justification in regard to this matter. If the terminology <br />should require change, it can be cited in their revised and/or <br />supplemental narrative with reference to the maps. In this way <br />the maps can be left unchanged. <br />C.) 43 CFR 3482.1 (c) (7) .."If a coal bed, or portion thereof, is <br />not to a mine or is to be rendered unminable by the operation, <br />the operator/lessee shall submit appropriate justification to <br />the authorized officer for approval." Exhibits 6-5 and 12-1 <br />show the Lennox coal seam within the proposed mining area at <br />strippable depths. However, no,justification is presented for <br />not recovering this coal. If justification can be <br />satisfactorily made at this time for not mining the Lennox, it <br />must not preclude the possibility of its recovery at some later <br />date according to an approved mine plan amendment. <br />h <br />