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2.06.9 Auoerino <br />2.06.9 applies to any person who conducts or intends to conduct surface coal mining and <br />reclamation operations utilizing augering operations. The operator has chosen to apply the <br />requirements of this section to the proposed highwall mining in new Attachment 12-4, due to the <br />similarity of the mining method and potential impacts to auger mining operations. We concur with <br />this approach, given Division precedence and the fact that the rules do not specifically address <br />highwall mining. Items 8 through 17 below are our review comments on the highwall mining <br />operational plan as presented in Attachment 12-4. <br />8. Rule 2.06.9(2) requires that the application contain a description of the augering methods <br />to be used and the measures to be used to comply with 4.23. <br />The operational description lacks necessary detail, and there is one conflict in the <br />descriptions of which coal seams are to be mined by the highwall mining method. On <br />page 12-4-1 highwall mining is proposed in the Wadge and Wolf Creek coal seams. On <br />page 12-4-2, highwall mining is proposed in the Wadge, Sage Creek and Wolf Creek coal <br />seams. <br />Please amend the text to be consistent regarding which coal seams are to be <br />mined by the highwall miner. Please expand the proposed mining plan description <br />of multiple-seam highwall mining to include the vertical relationships of mining <br />activities. Please indicate on Exhibit 12-3 those areas of multiple-seam mining, <br />including the identity of the seams. Please identify to which seam the currently <br />drawn proposed penetrations and limits of highwall mining apply, and provide a <br />cross section that illustrates the staggering, if any, of lines of highwall hole face- <br />ups and limits of penetration. <br />Rule 2.06.9(3) states that no permit shall be issued for any operations covered by 2.06.9 unless <br />the Division or Board finds, in writing, that in addition to meeting all other applicable requirements <br />of these Rules, the operation will be conducted in compliance with 4.23. <br />Rule 4.23.1 establishes environmental protection performance standards in addition to those <br />applicable performance standards in Rule 4, to prevent any unnecessary loss of coal reserves <br />and to prevent adverse environmental effects from auger mining incident to surface mining <br />activities. <br />9. Rule 4.23.2(1) requires that auger mining (interpreted by the Division to include highwall <br />mining), shall be conducted to maximize recoverability of mineral reserves remaining "' <br />after mining activities are completed. To this end, the rule further specifies that areas of <br />undisturbed coal be left in place in accordance with specifications listed in 4.23.2(1)(a), <br />(b), and (c), to provide access for removal of those reserves by future underground <br />mining activities, unless the Division determines that the coal reserves have been <br />depleted or are limited in thickness or extent to the point that it will not be practicable to <br />recover the remaining coal reserves. <br />