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<br />1. Adequacy of the <br />osed Resource Reco <br />n <br />and Protection Plan and <br />The submitted Resource Recovery and Protection Plan (R2P2) is deficient in <br />the following areas: <br />A. An estimate of the coal reserve base, minable reserve base, and <br />recoverable coal reserves for the Federal lease needs to be <br />included in the R2P2 (43CFR 3482.1(G)(3)(iii)). This information <br />can be included as an Appendix and inserted in the confidential <br />volume. <br />9. An explanation of how Maximum Economic Recovery (MER) will be <br />achieved for Federal coal needs to be included in the R2P2. (43 <br />CFR 34E2.1(b)(7)). This narrative should discuss all areas of <br />the mine individually, and specifically address mining conditions <br />and how they relate to MEk. <br />C. The initial spoils are to be placed over areas of unmined coat <br />resource. A discussion of the spoil placement on the future <br />recovery and MER of the underlying coal in these areas is <br />necessary. <br />D. The Golder Associates report (Exhibit 19) contains a discussion <br />of truck shovel operations in the permit area on Federal coal. <br />If this equipment is to be used, it should be discussed in the <br />text of the permit and included in the equipment list. <br />Although the permit package is fora 5 year period, the R2P2 is a <br />life-of-mine document and information contained therein should <br />reflect this status. <br />Compliance with Special Lease Sti~u]ations and A~licable Agency <br />Regulations <br />The lessee is currently in compliance with all special lease <br />stipulations. However, the proposed method of permanently searing <br />exploration holes, bore holes and wells outlined under rule <br />2.05.4(2)(8), page 2.05-76 and 2.05-77 is not in compliance with 43 <br />CFR 3483.1(a)(3). Our agency regulations require, under Federal <br />Teases and licenses, that holes drilled deeper than the surface coal <br />stripping limit shall be plugged through the thickness of the coa] <br />beds and through aquifers for a distance of at least 50 feet above <br />and below the coal beds and aquifers. Therefore, the subject plan is <br />not in cempliance with our agency regulations as they pertain to <br />exploration hole plugging. <br />