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M. Long <br />February 25, 1994 <br />Page 3 <br />8. To date, there has not been a current map provided by <br />Basin indicating the lateral extent and pay thickness of <br />coal seams underlying the proposed permit area, <br />specifically, under Rancho Escondido. Raton West <br />recognizes the potential proprietary nature of such <br />information; however, as Basin's position is that it <br />holds all of the coal mineral interests within the <br />proposed permit area, disclosure of such data would not <br />unfairly benefit competitors. Such disclosure would, <br />however, provide data necessary to Raton West and its <br />successors in interest with regard to assessing potential <br />subsidence effects. <br />As the Division is aware, new OSM regulations regarding <br />underground mining, particularly subsidence issues, are anticipated <br />to be adopted later this year. By submitting these supplementary <br />comments to the state, Raton West does not waive its right to <br />revise or supplement its comments on any subject matters covered by <br />the provisions of the Proposed Golden Eagle Mine Permit, should <br />such matters be subject to the new OSM provisions. <br />In addition to Exhibits 1 through 35 previously endorsed by <br />Raton West, Raton West also endorses as Exhibits all materials <br />submitted by Basin pursuant to the present permitting process. <br />Very truly yours, <br />KRASSA, LINDHOLM, KUMLI AND MADSEN <br />~tobi- r~A. Byers <br />RAB:akr <br />cc: Jeffrey H. DeSautels, Esq. <br />Steven G. Renner, Coal Program Supervisor <br />Daniel I. Hernandez, Senior Environmental Protection <br />Specialist <br />Steve Brown, Esq., Asst A.G. <br />Tom Fears, Esq., Asst A.G. <br />Krassa, Lrdho(m, Kamli & Madsen <br />