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Specifically the AAI Plan, in 3.2 Gas Pipelines, states: "It is anticipated that pipelines can be undermined using <br />full extraction techniques provided that the pipelines are decoupled from the surrounding ground". <br />The AAI Plan further recommends that "Gas pipelines should be uncovered and supported... before extraction <br />operations are within a 40' angle from the pipeline location" and " The pipelines should remain uncovered until <br />after... extraction efforts have progressed more than the distance defined by a 40'angle beyond the pipeline <br />location". <br />The AAI Plan offers these same recommendations under 3.3.4 Gas Pipeline Ancillary Structure Damage <br />Mitigation Plan, 3.44 Water Pipeline Damage Mitigation Plan, and 3.5 Water Pipeline Ancillary Structure <br />Damage Mitigation Plan. <br />In each of these cases the AAI Plan refers to pipelines that are fully developed, for which reclamation has already <br />occurred. The AAI Plan creates additional surface disturbances, which runs contrary to the intent of the coal mine <br />lease. In addition, implementing these recommendations would place XTO in direct violation of CDOW's SUA <br />for pipeline construction. <br />CDOW is concerned about additional surface disturbance, length of time the pipelines are decoupled from the <br />ground, the amount of time the pipelines remain uncovered, the hazard that open trenches pose to wildlife and <br />public, the impacts on the state's ability to perform routine management operations, possible violations of the <br />SUA, and interim and final reclamation. <br />The CDOW remains committed to not allowing additional surface disturbances other than those that were <br />specifically identified in the states coal lease to NECC. <br />CDOW respectfully requests that appropriate mitigation that addresses these issues be developed prior to <br />commercial operation. <br />The Division of Wildlife would like to express its thanks to the Division or Reclamation, Mining and Safety for <br />providing the opportunity to review these documents. If you have any questions regarding this letter, please <br />contact Al Trujillo, Energy Specialist at (719)227-5232. <br />Sincerely, <br />David C. Lovell Z <br />Assistant Regional Manager <br />Southeast Region <br />Cc: Dan Prenzlow, Southeast Region Manager <br />Mike Trujillo, Area Wildlife Manager <br />Bob Holder, DWM-Trinidad West <br />Bill Velarde, WT-Bosque del Oso SWA <br />