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Reference is made to the 1989 permit boundary. The usage of that term is confusing and <br />vague, at best. Please ensure all maps and text identifies a permit boundary for the area as <br />proposed under this revision. <br />6. Revised surface and coal ownership maps were not submitted showing the proposed permit <br />boundary. Please refer to Rule 2.10, Maps and Plans, and ensure that these maps, in <br />addition to all other maps comply with the requirements of Rule 2.10 and show the new <br />permit boundary as proposed. <br />7. Information required under Rule 2.05.6(6), Subsidence Survey, Subsidence Monitoring, and <br />Subsidence Control, was only partially submitted. All structures require a brief description <br />and require location on a map. Roads, buildings, wells, pipelines, compressor stations, <br />stock ponds, and any other man-made structures are considered structures under this Rule. <br />The applicant must describe the worst possible consequences for each of the structures and <br />subsidence control plans and monitoring for each. At this time, the subsidence control <br />plan, monitoring, and mitigation for the gas wells has been developed assuming Allen seam <br />mining. Please refer to #10 below. <br />8. Maps submitted with the application have a scale that appears inaccurate. Please review the <br />scale of the maps and ensure that they are correct and in accordance with Rule 2.10. <br />9. Maps are also illegible, especially regarding annotation of specific features. Please ensure <br />all maps are legible and all information can be clearly identified, both visually and by the <br />map legend. <br />10. From information submitted to the Division, as Minor Revision No. 93, it appears that <br />future mining in the Allen seam is unlikely. While multi-seam mining can be approved, it <br />is not clear what the specific mining plan is for the New Elk mine. Without specific <br />information regarding which coal seam will be mined at the site, it is not possible to <br />develop appropriate subsidence control plans or mitigation, if necessary. Permitting <br />alternative mining scenarios requires detailed information be submitted for both scenarios. <br />This information does not appear to be present in the current application and is not present <br />in the currently approved permit application. <br />In summary, for the new lands to be included in the permit area, all information as required under <br />Rules 2 and 4 of the Coal Regulations is required. If you have questions, please call me. <br />Sincerely, <br />Kent A. Gorham <br />Environmental Protection Specialist III