2010-08-25_REVISION - C1981012 (2)

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Kent Gorham - August 21,20 10 - page 3. 5. Reference is made to the 1989 permit boundary. The usage of that term is confusing and vague, at best. Please ensure all maps and text identifies a permit boundary for the area as proposed under this revision. Maps have been modified to identify the permit boundary as proposed. 6. Revised surface and coal ownership maps were not submitted showing the proposed permit boundary. Please refer to Rule 2.10, Maps and Plans, and ensure that these maps, in addition to all other maps comply with the requirements of Rule 2.10 and show the new permit boundary as proposed. Map 1 has been revised to show the surface ownership. Map 2 has been revised to show the coal ownership. 7. Information required under Rule 2.05.6(6), Subsidence Survey, Subsidence Monitoring, and Subsidence Control, was only partially submitted. All structures require a brief description and require location on a map. Roads, buildings, wells, pipelines, compressor stations, stock ponds, and any other man-made structures are considered structures under this Rule. The applicant must describe the worst possible consequences for each of the structures and subsidence control plans and monitoring for each. At this time, the subsidence control plan, monitoring, and mitigation for the gas wells has been developed assuming Allen seam mining. Please refer to #10 below. The Allen Seam and Apache seam lie within 10 to 30 ft of each other within the proposed permit boundary. Predications of impacts at the depths is accurate for mining either seam. Refer to the revised Exhibit 24. Maps submitted with the application have a scale that appears inaccurate. Please review the scale of the maps and ensure that they are correct and in accordance with Rule 2.10. All maps have been reviewed for accuracy of scale and modified if necessary. 9. Maps are also illegible, especially regarding annotation of specific features. Please ensure all maps are legible and all information can be clearly identified, both visually and by the map legend. Mapping for this permit application is under transition from mylar to digital. The scanned images of the historic maps have been included as an image for reference. 10. From information submitted to the Division, as Minor Revision No. 93, it appears that future mining in the Allen seam is unlikely. While multi-seam mining can be approved, it is not clear what the specific mining plan is for the New Elk mine. Without specific information regarding which coal seam will be mined at the site, it is not possible to develop appropriate subsidence control plans or mitigation, if necessary. Permitting alternative mining scenarios requires detailed information be