2011-03-25_REVISION - C1981012 (2)

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03/25/2011 08:35 FAX 7192275297 DOWCOS fa003/005 The AAI Plan was performed to predict mining-induced subsidence over pmjected room-and-pillar panels in the Allen or Apacho Seams at New Elk Mine. The AAl Plan further provides recommendations to mitigate any surface subsidence. Specifically the AAI Plan, in 3.2 Gas Pipelines, states: `°1<t is anticipated that pipelines can be undermined using fu11 extraction techniques provided that the pipelines are decoupled from, the s?orot ing groraA', The AAI Plan further recommends that "Gas pipelines should be rmcovered and supported... before extraction operations are within a 400 angle fnDm the pipeline location" and- The pipelines should remain umcovered until after, ,,extraction efforts have progressed more than the distance defined by a 40°angle beyond the pipeline location". The AAI plan offers these same recommendations under 3.3.4 Gas Pipeline Ancillary Structure Damage Mitigation Plan, 3.44 Water Pipeline Damage Al iidlgation Plan, and 3.5 Wader Pipeline Ancillary Structure Damage litigation Plan. In each of these cases the AAI Plan refers to pipelines that are fully developed, for which reclamation has already occurred. The AAI Plan croates additional surface disturbances, which runs contrary to the intent of the coal mine lease. In addition, implementing these recommendations would place XTO in direct violation of CDOW's SUA for pipeline construction. CROW is concerned about additional surface disturbance, length of time the pipelines are decoupled from the ground, the amount of time the pipelines remain uncovered, the hazard that open trenches pose to wildlife and public, the impacts on the state's ability to perform routine management operations, possible violations of the SUA, and interim and final reclamation. The CROW remains committed to not allowing additional surface disturbances other than those that were specifically identified in the states coal lease to NECC. CDOW respecttWIY regaests that appropriate mitigation that addressee these issues be developed commercial operation. prior to The Division of Wildlife would like to express its thanks to the Division or Reclamation, Mining and Safety for providing the opportunity to review these documents. If you have any questions regarding this letter, please contact Al Trujillo, Energy Specialist at (719)227-5232, sincerely, David C. Lovell Assistant Regional Manager Southeast Region Cc: Dan Prenzlow, Southeast Region Manager Mike Trujillo, Area Wildlife Manager Bob Holder, DWM-Trinidad West Bill Velarde, WT-Bosque del Oso SWA