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Ms. Candace Thompson <br /> October 29, 1985 <br /> Page two <br /> The other major change that needs to be made to the permit <br /> boundary is to the western and southern boundaries as they now <br /> exist. A quick look at the maps, Exhibits II-A-1 and II-B-1, <br /> will reveal that the only difference between the present mine <br /> plan area and permit area is the amount of the area above the <br /> underground workings that is included within the permit area as <br /> compared to the inclusion of the entire federal lease areas in <br /> the mine plan area. <br /> Modifications in the underground mining plan that have <br /> recently been submitted for approval by the BLM for the remainder <br /> of this 5 year permit period require adjustment of the permit <br /> boundary to accommodate revised locations of longwall panels 104 , <br /> 208 and 209 as well as several access mains and submains . See <br /> attached BLM letter of October 15, 1985. Also, the permit boundary <br /> should extend beyond the areal extent of the underground workings <br /> a sufficient distance to account for an acceptable subsidence <br /> angle of draw. The angle of draw problem can be solved for the <br /> mine plan area by extending the boundary beyond the federal lease <br /> boundaries a sufficient distance to allow mining up to 50 feet <br /> from the lease boundaries. See attached letter from the qunnison <br /> National Forest dated February 13 , 1985 authorizing this. <br /> With respect to the western and southern boundaries of the <br /> permit area, we believe that they might as well coincide with the <br /> mine plan area boundaries. We forsee continual modifications in <br /> the mining and degassification plans over the life of the mine <br /> that will make it extremely difficult to accurately define the <br /> western and southern boundaries for the individual five year <br /> permit periods. Planning is also underway to extend the rock <br /> tunnel to a west portal site that will be near the west boundary <br /> of the mine plan area. Once the exact location is selected and the <br /> detailed plans developed for the west portal facility, it, together <br /> with the existing access road, must be included in the permit <br /> area. <br /> All baseline environmental data for the original Coal Basin <br /> mine permit application, contained in Volumes 4 , 5 & 6 , was <br /> collected for the mine plan area and immediate vicinity. Therefore, <br /> expansion of the permit area to the west and south should require <br /> no additional general environmental data. Site specific environ- <br /> mental data for any areas to be disturbed west of Huntsman Ridge <br /> will be provided as part of their permit application as is being <br /> done for the gas well access road on that side of the mountain. <br /> This adjustment of the permit boundary will not affect <br /> reclamation bonding as it does not involve changes in surface <br /> disturbed areas. <br />