REV01051

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 1/19/2001
• Doc Name: BOWIE NO 2 MINE PR 04 CHANGE IN MINE PLAN IRON POINT TRACT FEDERAL LEASE ADEQUACY RESPONSE NO 1 PN C
• From: J E STOVER & ASSOCIATES
• To: DMG
• Type & Sequence: PR4
• Media Type: D
• Archive: No

J. J. Dudash - 9 - January 17, 2001
BRL - No Response Required.
The USFS adequacy review letter, dated December 15, 2000, in which the
USFS has several adequacy review questions for PR-04.
BRL -Responses follow USFS concerns.
a. Map 14- Mine Plan. The permit submission indicates that Bowie has
secured with Oxbow Carbon and Minerals to mine coal on the east
end of panels D6, D7 and D8 (section 2.03.6). Panel D8 underlies
NFSL and extends into the Hubbard Creek corridor. Stipulation
15(f)(A) on the federal lease (stipulation 4 of the ROD) states that
mining that would cause subsidence wil! not be permitted under
Hubbard Creek or within a zone created from projecting a 25 degree
angle of draw (from vertical) from the surface expression of the
creeks down to the top of the coal seam to be mined. The mine plan
does not appear to have accounted for this stipulation. In addition,
this stipulation calls that this same protection to be applied to Dove
Gulch. The mine plan does not account for protecting Dove Gulch.
In addition, stipulation 15(a)(4) on the federal lease calls for
protecting Dove Cave from the negative effects of subsidence. This
has not been addressed in the permit revision. Bowie will need to
revise the mine plan to comply with these stipulations.
BRL -The response to the Division concern No.23 above applies to
the USFS concern over the Oxbow Carbon and Minerals coal.
Please see discussion in (b.) below regarding the 25 degree angle
of draw. The Operator believes the perennial portions of Dove
Gulch have been protected from the effects of subsidence based on
the December 2000 revised mine plan. See Map 27 which shows
that Dove Cave is outside of the projected extent of subsidence.
Map 27-Subsidence. This map shows a "limited extraction zone"
lining the Hubbard creek corridor. However, it is not clear how this
zone was determined. It should correlate to the 25 degree angle of
draw zone required from the stipulation noted in item 1. Bowie
needs to supply the calculations and information used in
determining this zone. Further, the map also shows two lines
depicting the extent of subsidence, one without limited extraction,
and the other with limited extraction. It is not clear why both these
lines are included on the map, as the EIS and ROD do not permit
subsidence in Hubbard Canyon as described in item 1. The FS
requests explanation and supporting information pertaining to which
line represents the likely subsidence extent based on the stipulation.
As with Map 14, Map 27 does not show that the mine plan
accounted for protection Dove Gulch and Dove Cave. Bowie will