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Such determination by the Division can only be made upon presentation of appropriate <br />technical evidence by the operator, In this case, future underground recovery of the <br />remaining reserves would entail excavation of deeply backfilled pits to accommodate <br />driving entries through the undisturbed coal blocks, and this might indeed be <br />impracticable. However, the operator has not presented technical evidence to support a <br />variance from the requirement to leave unmined coal in place. Rather, the operator has <br />presented a plan that addresses the specific requirements of 4.23.2, leaving unmined <br />areas of coal in place. Our specific review comments regarding the operational plan <br />submitted are set forth below, in Items 10 and 11. However, given the circumstances, <br />the Division recommends that the operator consider the option of presenting <br />technical evidence of the impracticality of future coal recovery by underground <br />methods. If such technical evidence is submitted and accepted by the Division, <br />the highwall mining plan would need to be appropriately amended, without <br />provision for leaving undisturbed coal sections in place for future access to <br />facilitate underground mining. <br />If the operator does submit and the Division accept such demonstration, Items 10 and 11 <br />below will not be applicable. <br />10. Rule 4.23.2(1)(b) requires that unmined sections of coal be no more than 2,500 <br />feet apart, measured from the center of one section to the center of the next <br />section, unless a greater distance is set forth in the permit application under <br />2.06.9 and approved by the Division; <br />The text of the application is in compliance with this rule (see page 12-4-1) but the mine <br />plan depicted in Exhibit 12-3 does not correspond with the text. The distance from the <br />center of the north two pillars of the Wadge Seam (at the highwall) is 2,950 feet, and <br />between the south two pillars 3,400 feet. No pillars are depicted on Drawing 12-3 for <br />barrier pillars in the Wolf Creek Seam. It is not clear where the Sage Creek coal seam fits <br />in. Unless the requirement for undisturbed blocks of coal is waived, please revise <br />Drawing 12-3 to indicate 2,500 feet center-to-center spacing (at the face of the <br />highwall) of the blocks of undisturbed coal [Rule 4.23.2(1)(b)]. <br />11. Rule 4.23.2(1)(c) requires that undisturbed areas of coal shall be left in umnined <br />sections which, for multiple seam mining shall have a width of at least 250 feet <br />plus SO feet for each subjacent workable coal seam. The centers of all unmined <br />sections shall be aligned vertically. <br />Figure 12-3 indicates that highwall mining is proposed for approximately 600 feet in the <br />Wadge and Wolf Creek coal seams, but the "highwall mining limit" is shown as 1000 feet. <br />The operator has clarified by phone that the current equipment planned to be used will <br />only penetrate approximately 600 feet, but SCC would like to go 1,000 feet if possible at <br />the time of mining. If so, the Wolf Creek highwall mining would extend under the Wadge <br />highwall mining, and the requirements of this rule are not met by the application. In <br />