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One of the main concerns with longwall is increased subsidence and the entire <br />issue is sidestepped by saying it was covered in the original mine plan. <br />The subsidence section of the Bowie No. 2 Mine permit was revised earlier this <br />year via Technical Revision No. 8, which included a discussion of subsidence <br />projections for longwall mining. As your comment implies, subsidence above <br />longwall mining is typically of a greater magnitude than subsidence above <br />conventional mining. BRL's choice to discuss subsidence impacts greater than <br />what might be expected to result from conventional mining in the mine permit is <br />not prohibited by the coal mining regulations. Now that longwall mining is being <br />proposed, the Division feels that the potential subsidence impacts expected to <br />result from longwall mining are already adequately discussed in the permit. <br />Was mining multiple seams included in the analysis? <br />The Bowie No. 2 Mine permit indicates that mining of the B-2 coal seam may be <br />proposed at some time in the future. The approved operating plans at this time <br />include mining of the D seam only. No other mining is presently approved. <br />Therefore, the subsidence sections of the permit only address impacts expected <br />to result from removal of the D seam. <br />The documents dealing with subsidence were not made available to us at the <br />Paonia library for public review. <br />The Regulations of the Colorado Mined Land Reclamation Board for Coal Mining <br />require that mine operators place a copy of proposed permit revisions in a public <br />office where they will be available for public review. Since the subsidence <br />section of the Bowie permit was not revised in PR-02 or PR-03, BRL is not <br />required to place that portion of the permit in the Paonia library. The entire <br />approved mine permit is available for public review at the Bowie mine office and <br />at the Division's office. The permit was also available in the Delta County Clerk <br />and Recorder's office prior to the time the Division directed BRL to send <br />permitting material to the Paonia library for the public's convenience. I am not <br />certain if that copy is still in the Clerk and Recorder's office at this time. <br />In summary, the Division feels the BRL has addressed the issues which you <br />presented in your letter adequately to comply with the applicable law and <br />regulations. BRL and the Division are currently working to resolve the final <br />details with the two remaining issues from the Division's June 18, 1999 <br />preliminary adequacy review letter to the company. Those issues are the <br />revision of the mine's water depletion estimate and clarification of ownership <br />information in the permit. Once those issues are adequately resolved, we <br />anticipate that a proposed decision will be issued by this office in a matter of <br />days. <br />