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late 1986, and production from the property resumed in January 1987. Since access to the coal and production of the remaining reserves from the sealed mine areas was felt • possible st a future date, when the fire had completely cooled, the mine fire had little affect on the long term mine plan projections and coal recovery, and main effect of the fire on the R2P2 was the change in panel sequencing. On the basis of the mina lira, CWI applied for and received a force majaura suspension until normal production could be resumed. As CWI resumed production at the new Bite, it became clear that the mining problems which had plagued them in the original mine were cos®on in the west area of the property also. CWI continued to cope with these problems, ae beet they could, on e case by case basis through minor modifications of the approved mina plan. In November 1988 Cyprus Coal Company acquired ownership of CWI, and changed the name of CWI to Cyprus Orchard Valley Coal Corporation (COV). Mina operations and mining conditions under COV ware similar to CWI, and while COV attempted several modifications to improve mining conditions, it was clesr that more drastic changes would be necessary if mine operations wore to have any hope of being safe and remaining competitive in the existing coal market. Shortly after acquiring the property, COV undertook a number of coat reduction measures, and in August 1990 they applied for a reduction in Padaral royalties on leases C-37210 end C-27432 {C-25079 and D-036955 era nearly mined out) from 8t to 2t under the expanded recovery/financial teat category. On the basis of data submitted in that application, they were granted s reduction in royalty to 4i for coal mined while developing access to the remaining reserves on C-37210. CCV, rather than continue with the praviou• band-aide approach to the persistent mining problems, has comprehensively reexamined the reserve base on the property with the aim of identifying those areas which can ba mined ssfely, economically, and within marketable contract specifications. To do this, Cyprus personnel have reviewed all mining records and experience gained to data for the property to establish ^ome guidelines for the geologic conditions which result in mining • problems, and developed a detailed interpretive depositional geologic model to predict the probable location of areas which have the least likelihood of these troublesome geologic conditions. They have also adjusted mining operation parameters to achieve productivity levels necessary to compete in the present and foreseeable coal market conditions. Tha result of this effort is the revlsad R2P2 submitted for approval. Tha level of detail and systems approach used by Cypru^ in addressing the R2P2 requirements of 43 CFR 3482 makes the revised plan itself the bast description and analysis, and the reader is urged to review the revision for detail. Description of the Applicant's Proposal Briefly, the significant design parameter^ which COV developed from aetusl mining experience were: roof control, coal thickness, spontaneous combustion, ventilation, cleat system, structural geology, and eubeidanea. By far, the moat important of these in affecting the mine plan and raeouree recovery are the roof control and coal thickness considerations in that, taken together, they allow recovery of coal (with some limited •:oeptlons) oaly from the thick •pod• areas of the reserve base. Tha cleat system and structural geology control panel orientation and layout, spontaneous combustion sad subsidence 1Lsit areas open to recovery, and ventilation affects mine sequencing. With the coal thickness and roof control considerations established by COV to be paramount to the safe and economic operation of the mina, much of the geologic modeling was focused on detailing these parameters for the remaining areas in the reserve bees. The interpretative modeling done by Cyprus identified three areas of the D-seam where the upper and lower portions of the seem merge, forming pods of D- eeam coal sufficiently thick to provide for the minimum mining height while still leaving three feet of top coal for roof control. These areas were selected ae the • primary targets for resource recovery from what remains of the reserve base.