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Messrs. Shelton and Daws Page 2 <br />November 6, 1981 <br /> <br />Employees will continue to be laid off, defaults under market <br />commitments will worsen, and, in the broader perspective, the nation's <br />critical energy shortage will be aggravated. The revision does not seek <br />to expand production above the levels previously approved nor effect <br />significantly greater levels of disturbance. Mining will simply proceed <br />logically on existing Federal Coal Lease No. D-052501 for which Bear <br />Coal Company has authorization to mine. <br />In an effort to bring the problem to the attention of the Office of <br />Surface Mining ("OSM") and the Colorado Mined Land Reclamation Division <br />("Division") to facilitate and expedite review of this revision, the <br />Bear Coal Company has held a series of meetings with OSM and Division <br />representatives throughout the summer and early fall of 1981 for the <br />purpose of discussing and reaching some understanding on the permit <br />format, design criteria for certain structures in the mining area, and <br />environmental baseline information requirements in a wide variety of <br />areas. The substance of these discussions, including confirmation of <br />baseline parameters, has been set forth in correspondence from Bear Coal <br />Company to OSM and the Division. <br />We must emphasize that the revision is not for a new mine in virgin <br />country. It covers an operation that has been in existence for over 47 <br />years and one with an excellent standing in the community. Equally <br />important, the revision does not seek to expand the existing levels of <br />production requiring added employees or greater levels of disturbance. <br />hlining will simply proceed logically into the adjacent Federal Coal <br />Lease No. D-052501. <br />Both OSM and the Division have significant familiarity with Bear Coal <br />Company's present operations. The state has evaluated the Bear Coal <br />Company thoroughly through numerous permits, permit revisions, and <br />amendments over the past several years. Since much of this permit <br />revision covers ongoing operations, it is hoped that the past <br />familiarity will allow the review to progress speedily. <br />In conclusion, we hope that all these factors -- the Bear Coal Company's <br />critical need for reserves to keep its mine in operation, regulatory <br />familiarity with ongoing operations, significant prior environmental <br />analyses and minimal net environmental impacts -- will enable you to <br />expediently review and act upon this permit revision. We must reiterate <br />that without regulatory approval of this revision, Bear Coal Company <br />will be forced to greatly diminish and may ultimately terminate its <br />underground mining operations. <br />We know that this permit revision will be carefully scrutinized. <br />Recognizing this, we want to maintain open lines of communication. <br /> <br />