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<br />We are aware that Exhibit 47 contains several pages of [his type of information. However, <br />given the recent acquisition of Twentymile Coal Company by RAG, it is likely that portions <br />of Exhibit 47 need updating, to accurately reflect all operations currently owned or <br />controlled by current owners and controllers of Twentymile Coal Company. <br />Exhibit 47 may also need updating to remove those surface coal mining operations no longer <br />owned or controlled by current owners or controllers of Twentymile Coal Company. If so. <br />please revise the appropriate sections of Exhibit 47. <br />Exhibit 47 may also need updating to remove those persons (including companies) that are <br />no longer owners and controllers of Twentymile Coa( Company. If so, please revise the <br />appropriate sections of Exhibit 47. <br />15. Rule 2.03.4(4)(b): For all US surface coal mining operations owned or controlled by owners <br />and controllers of Twentymile Coal Company, please provide the information required by <br />this rule. <br />For example, Greg A. Walker is currently listed in Exhibit 47 as Senior Vice President of <br />Twentymile Coal Company. As such, he is considered an owner/controller of Twentymile <br />Coal Company. If Greg A. Walker is, as defined by Rule 1.04(83a), an owner and controller <br />of another surface coal mining operation in the United States, then the ownership/control <br />relationship of that operation to Twentymile Coal Company, including percentage of <br />ownership and location in organizational sttucture, should be provided in the permit. <br />To clarify this example further, assume for the sake of discussion that Greg A. Walker, an <br />owner/controller of Twentymile Coal Company, is an owner/controller of a coal mining <br />operation in West Virginia. Per Rule 2.03.4(4)(b), the Foidel Creek Mine permit should <br />contain a description of the ownership/control relationship of the West Virginia company to <br />Twentymile Coal Company. In this description, the Foidel Creek Mine permit should <br />additionally contain information regarding the West Virginia operation's percentage of <br />ownership of Twentymile Coal Company (if applicable), and the location of both the West <br />Virginia operation and Twentymile Coal Company in the overall organizational structure. <br />We are awaze that Exhibit 47 contains several pages of this type of information. However, <br />given the recent acquisition of Twentymile Coal Company by RAG, it is likely that portions <br />of Exhibit 47 need updating, to accurately reflect those operations currently owned or <br />controlled by current owners and controllers of Twentymile Coal Company. Exhibit 47 may <br />also need updating to remove those persons (including companies) that are no longer owned <br />or controlled by owners or controllers of Twentymile Coal Company. <br />16. Rules 2.03.4(4)(a) and (b): Certain information is provided on permit page 2.03-13 (rev. <br />10/01/97) in the current permit in response to these two rules. This specific information <br />appeazs in the second section on this permit page entitled "Response", and begins with "the <br />ultimate pazent of the above is Cyprus Amax Minerals Company". Given the recent <br />acquisition of Twentymile Coal Company by RAG, it would appear that this part of the <br />