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Steve Hinehmen, WSERC 49701527.5307 i~t/22199 m4:50 PM pM4 <br />• "Each application~l contain a complete attd detailed legal~cription of <br />the proposed permit bouttdary, a description of the documents upon which the <br />applicant bases his or her legal right to enter and begitt surface coal mining <br />operations in the permit area, and a statement as to whether that right is the <br />subject of pending litigation. The description shall identify those documents by <br />type and date of execution, identify the specific lands to which the document <br />pertains, and explain the legal rights claimed by the applicant..." <br />While the proposed action may technically apply to the current permit boundary and Bowie's fee coal <br />reserves only, the action is intended as paR of an overall mine plan that depends on access to 14 million to 24 <br />million tons of federal coal reserves. Some factors to reinforce this statement: <br />• Bowie's current reserves are less than 7.5 million tons. At 4 mty production, the fee coal would <br />be mined-out in less than 2 years; thus installation of a longwall is not economically feasible <br />without additional federal coal reserves. (thus. 50 to 70 percent of the total coal reserves to be <br />mined with this longwall are federal coal reserves, for cvhich Bowie has no "Right of Entry.") <br />• Bowie's 5-year mine plan shows their intent to orchestrate a "seamless" transition from their fee <br />coal into federal coal in less than two years. <br />• Bowie is already applying to the DMG and BL.M for a right of way through the federal coal <br />reserves in order to facilitate construction of the longwall for future mining of these same federal <br />coal reserves. <br />Bowie has a 10-year contract with the Tennessee Valley Authority to provide 3 million tons per <br />year -which is far in excess of their fee coal reserves, and can only be met by using a longwall <br />operation in the federal coal reserves. <br />Based on these factors, we request that the DMG cease consideration of TR # 7 until such time as the <br />applicant can show Right of Entry for the federal coal reserves to be mined. Baring that, we would consider <br />the proposal to be a serious economic risk and an ill-advised investment. Without adequate reserves it is <br />impossible to realize economies of scale inherent in a longwall operation. Thus the chances of default are <br />higher, and we would request that the DMG significantly readjust bond requirements upward to reflect this <br />risk. <br />Please understand that WSERC does not necessarily oppose construction of a longwall operation or <br />new coal handling facilities. We simply believe that it is premature to permit these facilities or amend <br />Bowie's mine plan until there has been full analysis of the impacts of the proposed actions. If the state will <br />allow our community that opportunity, we promise to make the most of it. We appreciate the opportunity to <br />comment and would be happy to answer questions of either the DMG staff or the Colorado Mined Land <br />Reclamation Board. <br />Sincerely, <br /> <br />Steve Iiinchman, Director <br />For the WSERC Board of Directors <br />