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Ms. Susan Morrison <br />August 16, 1991 <br />Page 2 <br />D Seam and B Seam mine plans. The revised mine plans also indicate revised longwall panel <br />width of 800 feet beginning with the longwall panel LW-6. The new lease contains 9.6 million <br />tons of recoverable clean coal reserve. <br />Resource Recovery and Protectiou Plan <br />A revised resource recovery and protection plan (R2P2) is being submitted to the Craig Office <br />of Bureau of land Management (BLM) to include the new lease. BLM's approval of the R2P2 <br />is expected within the next six weeks well before CMLRD's decision on this application will be <br />due. A copy of the R2P2 is also being submitted to you. <br />Effect of Mining on the Environment <br />The new lease area will be mined by longwall and room-and-pillar underground mining <br />methods. Surface subsidence of as much as 5 feet is expected in the area because of the <br />extraction of the longwall panels. WFU has in the past conducted a CMLRD approved <br />subsidence monitoring program over the longwall panel No. 1. Although maximum subsidence <br />of as much as 5.0 feet has been observed, yet no visible surface discontinuity or abrupt <br />topographical changes have been noticed. The only other surface disturbance will be for the <br />access to and drilling of some holes to vent methane from the longwall gobs. The surface <br />disturbance for this purpose should not exceed 19 acres. <br />The drafr environmental analysis (DEA CO-017-91-30) prepared by the U.S. Department of the <br />Interior addresses a number of environmental issues that could be affected by the mining activity. <br />The following discussions are to a lazge extent based upon the DEA. <br />Over one-half of the Red Wash Tract has already been inventoried at a Class III level. The <br />remainder of the area will be inventoried at a Class III level and, if significant sites are <br />discovered, impacts will be mitigated. All requirements of inventory and mitigation will be done <br />according to Section 106 of the National Historic Preservation Act of 1966 (as amended). <br />Of the 81 known sites in or near the Red Wash Tract area, three -- SRB1082, SRB1143, and <br />SRB1146 -- need consultation with the SHPO fot determination of eligibility to or listing on the <br />NRHP. Determinations of eligibility may require site testing at the request of BLM and SHPO. <br />All testing will be completed in accordance with a testing plan approved by BLM and SHPO. <br />A major concern is the potential damage to archaeological and historic sites as a result of mine <br />subsidence. Western Fuels has in the past developed and conducted a subsidence monitoring <br />program. The program was conducted in four phases. The first phase took place in September <br />