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?y 'A 1 <br />Letter to Mr. Cattany re: CAM-Colorado Permit Application C2008086 <br />April 7, 2009 <br />Page 4 <br />pads, and access roads. Unless and until CAM-Colorado provides such additional information, <br />DRMS cannot approve the company's permit application. <br />Although DRMS has historically addressed MDW permitting through the permit revision <br />process in response to data concerning the need for such facilities in a given mine, in this case <br />the need for and approximate location of the MDWs is known prior to DRMS's granting of the <br />permit. The need for methane removal beyond that provided through the central mine ventilation <br />system is clear. Map 14, which CAM-Colorado included with its permit application, provides an <br />approximate layout of the projected longwall panels for the first six years of the mine's operation <br />and consequently allows for an informed estimate of the location of MDWs along with the <br />required associated surface facilities. While the exact number and precise location of MDWs <br />may be modified as mining progresses, changes to the original plan submitted with the <br />application can be readily addressed through the mine permit revision process. A proposed plan, <br />based on best available knowledge, including here the need for MDWs and related surface <br />facilities, is essential prior to any DRMS decision on CAM-Colorado's permit application if <br />DRMS is to adequately exercise its oversight functions. <br />Thank you for your attention to this matter. We look forward to your reply. If you have any <br />questions about this letter, please contact us at 303-623-9466. <br />Sincerely, <br />Edward B. Zukoski, Staff Attorney Doug Pflugh, Research Analyst <br />Attorney for WildEarth Guardians and <br />Colorado Environmental Coalition <br />CC: Mike King, Deputy Director, Colorado Department of Natural Resources <br />David Berry, DRMS <br />Sandra Brown, DRMS <br />Jeremy Nichols, WildEarth Guardians <br />Roger Singer, Sierra Club <br />Joe Neuhoff, Colorado Environmental Coalition