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map (i.e. Map 51) is all that MCC should have permitted and included as affected acres. MCC <br />asserts that this interpretation is wrong, as the actual, projected or anticipated underground <br />workings, as well as the envisioned or anticipated sequence of mining are only one component <br />of the affected acres of an underground mining operation, and that the foreseen or <br />envisioned (i.e. anticipated) sequence of mining shown on a map and described in the <br />permit was not intended as nor does it represent a mining or "mine plan" boundary or limit. <br />When read completely and in its entirety, it is obvious that this regulation (and as stated in the <br />Act at Section 34-33-110(2)(n), Accurate maps or plans, of an appropriate scale, clearly <br />showing the land to be affected as of the date of application ..." and at Section 34-33- <br />110(2)(o), "Cross sections, maps, or plans of the land to be affected, including the actual <br />area to be mined ...") seeks to ensure that a sufficient area of land and associated resources <br />are accounted for and represented (i.e. described) in the permit area's resource studies, <br />impact analyses and other sections of the permit text (i.e. "narratives") and maps (not just <br />maps and plans as alleged) by envisioning the maximum (i.e. "over the life of the operation") <br />land and resource area that might possibly be affected by the planned underground mining <br />and associated surface operations (e.g. methane drainage wells (MDWs) and associated <br />roads.) As this rule requires, MCC's affected area includes the entire area of leased minable <br />coal reserves (i.e. "over the life of the operation") within the permit boundary that is defined in <br />Rule 1.04(86) to "... circumscribe the permit area ... Permit area includes all areas of land <br />which are or will be affected by surface coal mining and reclamation operations during the <br />term of the permit." This is documented on the decision forms for both the South of the <br />Divide (PR-10) and Dry Fork lease (PR-12) permit revisions, adding 5,250 acres and 1,517 <br />acres respectively (totaling 6,767 acres) to the permit area, and 4,830 acres and 1,517 acres <br />respectively (totaling 6,347) to the affected area acreages. As such, the affected area is <br />inclusive of significantly more than the area just above the projected underground workings, <br />and the entire affected area is contained within the permit boundary and has been completely <br />described in the approved permit document, including maps. Therefore, MCC was and <br />remains in compliance with this regulation. <br />? "2.05.3(2)(b) - Operation Plan - Permit Area - Underground Mining. A detailed <br />narrative* and appropriate map(s), prepared according to the standards of 2.10, <br />sufficient to describe* all proposed* surface disturbances to be associated with the <br />underground mining activities' within the permit area. Each operation plan shall <br />include a narrative, cross sections, map(s) and timetable(s) suffcient* to describe* <br />the areal* extent* of the proposed* underground workings and the stratum to be <br />affected." <br />*detailed narrative = wide-ranging story or description of actual or fictional events <br />*describe = to give a verbal account of, represent or illustrate something. <br />*proposed = to put forward for consideration; suggest, offer <br />*sufficient = as much as is needed, enough; adequate <br />*areal = regional, zonal <br />*extent = range; extensive space or area <br />3