REV91728

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 5/18/2006
• Doc Name: Adequacy Review & Attachments
• From: DMG
• To: Bowie Resources, LLC
• Type & Sequence: PR10
• Media Type: D
• Archive: No

United States Forest Paonia P.O. Boa 1030
USDA Department of Service Ranger District N Rio Grande Ave.
Agriculture PHONE NO. 970-527-4131 Paouia, CO 81428
FAX [phone]
File Code: 2820-4
Date: May 2, 2006
Mr. Joe Dudash
Reclamation Specialist
Colorado Division of Minerals and Geology
1313 Sherman Street, Room 215
Denver, CO 80203
RECEIVED
MAY ~ 4 2006 " ~
Dear Joe,
~visi0n of Minerals d Geology
The Grand Mesa-Uncompahgre-Gunnison National Forests (GMUG) has reviewed Bowie
Resources Limited's (BRL) proposed Permit Revision 10 (PR-10) to expand the B Seam mine
plan to the north. The Division has requested verification of access to federal coal reserves in
this proposed revision. Leasing these reserves was documented in the North Fork Coal Final
Environmental Impact Statement, and the GMUG consented to BLM leasing these federal coal
reserves with stipulations for the use and protection ofnon-mineral resources in a Record of
Decision dated March 2000. BLM issued federal coal lease COC-61209 on September 1, 2000
(modified January 1, 2004) for the lands in PR-10.
BRL's PR-10 proposes mining activities that have stipulated restrictions, or specific
requirements for protecting surface resources that were included in the federal coal lease
stipulations. These specific activities and our review of permit adequacy are given below (the
GMUG review comments aze in italics):
Develop main entries under Hubbazd Creek. Federal coal lease stipulation (f)(D) states, "The
structural integrity of the coal in chain and barrier pillars under Terror and Hubbazd Creeks shall
be designed and maintained for long term support. Backfilling or structural supports maybe
required to achieve long term support under the creeks and the stntcture upon retreat mining.
The results of a pillaz stability analysis shall be used in the design and upon abandonment to
determine that structural supports maybe required."
PR-10 proposes to drive the 3'd North Main entries under Hubbard Creek on national forest
lands. In consultation with BLM, we find that the pillar stability analysis submitted as part of
PR-10 fulfills the requirements of Stipulation (n(D), and adequately demonstrates that long term
support will be achieved.
A longwall panel will be developed under Dove Gulch. Federal coal lease stipulation (f)(A)
states, "Except at specifically approved locations, mining that would cause subsidence will not
be permitted within a zone under Terror Creek, Hubbazd Creek, and within 100 feet of the
outside line of the right-of--way of Hubbard Creek County Road and under Dove Gulch."
The GMUG Record of Decision further identifies that this stipulation applies to perennial
portions of Terror Creek, Hubbard Creek and Dove Gulch. As part of PR-10, BRL submitted a
V Caring for the Land and Serving People Pnn~eO on aecyaea raper