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• a III IIIIIIIIIIIII III <br />999 <br />INTERNAL MEMO <br />TO: Mike Long <br />FROM: Jim Burnell <br />SUBJ: West Elk Violation, NOV CV-99-015 <br />6 January 2000 <br />When Mountain Coal Company added acreage to their permit through Permit Revision No. 06 <br />(Apache Rocks addition) the addition included a north-projecting salient into the SW '/< of <br />Section 15 of approximately 48 acres. Mountain Coal's plans at that time, as shown on mine <br />plan maps included in the revision, did not involve mining within that 48-acre area. <br />Subsequently, the federal mine plan action was not written to include the area in question. <br />Later, revised maps accompanying Permit Revision No. 08 showed development within that 48- <br />acre salient in Section 15. The Division discovered in November of 1999 that Mountain Coal <br />Company had actually begun development within that area, including the removal of <br />approximately 39,000 tons of coal. Officially, since PR-08 has not yet been approved, the old <br />map was the valid one. <br />The violation was written on that basis. <br />