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J.E. Stover & Associates -10- May 31, 1996 Bowie No. 2 Mine conditions. Entry spacing will range between 50-feet and 120- feet, while cross cut spacing will range from 50-feet to 150- feet. It is suspected that the stated ranges of underground entry and cross cut spacing are to vague to allow projection of subsidence consequences. This issue will be revisited under the subsidence predictions in 2.06.5(6). Map 14, entitled "Mine Plan", depicts the "Possible Fault" as intersecting the three mains at the portal location. It is suspected that this will cause some operational difficulty, reminiscent of the problems encountered by Mountain Coal while facing up the F-seam portals of the Mountain Gunnison No. 1 mine. The resulting engineered remedial construction cost several million dollars and was marginally effective. The portals continue to evidence displacement fifteen years later, necessitating continued remedial expenditures. 2.05.3(2) Operation Description - Underground Mining The majority of the following comments in this section apply uniformly to all the proposed surface facilities at the Bowie No. 2 mine. BRL included a facsimile of Raye Junge's Colorado Geological Survey Map 06), and excerpts from it's accompanying text (Exhibit 12, Volume III) in the application. Mr. Junge's map was entitled "Geologic Hazards in the Hotchkiss-Paonia Reservoir Area, Gunnison and Delta Counties, Colorado". BRL presents its proposed surface facilities on Maps 15-1 and 15-2 of the application. While comparison is complicated by the significantly differing scales of maps 06 and 15-1 & 2, it appears that the majority of the proposed BRL surface facilities lie within areas mapped by Mr. Junge as landslides. The vent shaft pads, the portal bench, and the coal stockpile bench appear to lie within a recent landslide zone (ls1). The conveyor, haul road and stockpiles lie within a larger and older landslide zone (lsz). The explanation to Mr. Junge's map explains these hazard designations as follows. "LANDSLIDE: A landform resulting from the moderate to rapid, downward and outward movement of rock and/or soil where there is a surface or zone of weakness that separates the landslide from more stable underlying material. Landslides, including earthflows, result from the mass movement of rock and/or soil in response to gravitational stresses and these movements may affect adjacent downslope areas. Natural and man-caused disturbance of landslide areas could initiate additional instability and mass movement. Relative age of landslides is indicated by