2010-11-16_GENERAL DOCUMENTS - C1996083

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Public comment letters were received from individuals, citizen groups and businesses. The Division also received many telephone calls from the public. The positive comments centered on benefits to the community and the quality of the coal to be mined. The negative comments involved the need to combine the revisions into one revision, delay the revision decisions until the Environmental Impact Statement was finished and impacts to the environment and to society. The Division sent its adequacy letters for Technical Revisions Nos. 6 and 7 on February 8, 1999. However, after a request from the Division, BRL withdrew Technical Revisions Nos. 6 and 7, with the understanding that the proposed changes would be resubmitted in one permit revision. The proposed decisions to withdraw Technical Revisions Nos. 6 and 7 were made on February 17, 1999. The Division sent letters to all of the commenters, informing them of this change in proceedings and that their comments on Technical Revisions Nos. 6 and 7 would be carried over to the new submittal. However, BRL decided later to submit two separate permit revisions; Permit Revision No. 2, involving longwall mining at the current rate of 2 million tons per year and Permit Revision No. 3, involving associated facilities and an increase in production to 5 million tons per year. When BRL submitted Permit Revision Nos. 2 and 3, the operator was responding to the Division's adequacy questions from the previously withdrawn Technical Revision Nos. 6 and 7. Permit Revision No. 2 was submitted on May 5, 1999, and called complete on May 14, 1999. Permit Revision No. 3 was submitted on May 17, 1999 and called complete on May 27, 1999. Completeness letters were mailed to the same agencies and organizations that had received completeness letters for Technical Revision Nos. 6 and 7. The Division received several comment letters, both from governmental agencies and from the public. The Division's first adequacy letter for Permit Revision No. 2 was sent on June 18, 1999. In two letters, dated July 6, 1999 and August 12, 1999, BRL responded to the Division's adequacy concerns. The Division sent its first adequacy letter for Permit Revision No. 3 on July 23, 1999. BRL responded to those adequacy questions in letters dated July 27, 1999, August 30, 1999 and October 4, 1999. In several letters dated July 16, 1999, the Division received further comments from members of the public. In addition to raising concerns similar to their concerns raised in Technical Revisions Nos. 6 and 7, there were questions about the effects of subsidence, mining through a fault and water rights. Also, there were several requests for an informal conference and a request to place the BRL permit revision material in a location closer to the mine area, rather than in Delta. The informal conference was held on August 5, 1999. The Division discussed the content of Permit Revisions Nos. 2 and 3 and the company's responses to the Division's adequacy review of Permit Revision No. 2. The operator did not have time to respond formally to the Division's adequacy review of Permit Revision No. 3 at that time. The Division also answered questions and received additional comments from the public concerning the proposed changes to BRL's mine plans. The Division also received two letters from the public after the informal conference. Concerns with subsidence impacts, surface and groundwater impacts to water rights and water resources and the separation in the submittal of the various mine plan revisions. At the time of the first informal conference, the company did not have time to respond formally to the Division's adequacy review of Permit Revision No. 3. Therefore, a second informal conference was held on September 13, 1999. As at the first informal conference, the Division answered questions and received further comments from the public concerning the changes proposed in BRL's mine plans. 6