2009-04-06_APPLICATION CORRESPONDENCE - C2008086

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e 14 -% Letter to Mr. Cattany re: CAM-Colorado Permit Application C2008086 Page 2 April 7, 2009 Id. at 2-30 (emphasis added). See also id. at 4-70 ("it will likely be necessary to install two or three methane degasification wells in each longwall panel."); id. at 4-71 ("because three of the existing Colorado mines have degasification systems and larger mines are more likely to have degasification systems, the Red Cliff Mine is assumed to have a degasification system...."). Methane degasification wells will require significant surface infrastructure. To drill these wells, CAM-Colorado will need to construct new roads, or use or upgrade existing two-tracks, to the appropriate location, clear a well pad (typically 1-2 acres in size), and use a drill rig to bore down to the coal seam. "Once the location of wells is determined, development of roads would be necessary to transport drilling equipment to the site." DEIS at 2-30. II. CAM-Colorado's Permit Application C2008086 Fails to Address Methane Degasification Wells and Related Surface Disturbance. On March 10, 2009, Doug Hugh of Earthjustice reviewed permit application C2008086 at DRMS. The application consists of six volumes contained within eight binders. Mr. Pflugh thoroughly reviewed the application binder (Volume I) and the accompanying maps (Volume II). These two volumes provide the primary substance of the application. Mr. Hugh also reviewed the Exhibits (Volume III), and scanned the remainder of the application. During the course of his review, Mr. Pflugh found no discussion of methane mitigation or MDWs within the permit documents. Indeed, Mr. Hugh could not find the word "methane" anywhere in Volume I, the text of the permit application. While the permit application does discuss the mine ventilation fan located at the mine mouth, it does not mention safety concerns related to methane or consider surface facilities other than entry, processing, and transportation components at or adjacent to the mine mouth. Further, none of the maps Mr. Hugh review displayed MDWs, well pads, or roads to be used to access or construct MDWs. III. Because CAM-Colorado's Permit Application C2008086 Fails to Address Methane Degasification Wells, DRMS Must Find the Application Incomplete. Because the permit application lacks information concerning the location and disturbance accompanying proposed MDWs, DRMS cannot approve the permit, and must inform CAM- Colorado that its application is incomplete. DRMS rules require that coal mining and reclamation be permitted only if the activities can be "feasibly accomplished": No permit or permit revision application shall be approved, unless the application affirmatively demonstrates and the Division or Board finds, in writing, on the basis of information set forth in the application or from information otherwise available, which is documented in the approval and made available to the applicant, that: (a) The permit application is accurate and complete and that all requirements of the Act and these Rules have been complied with.