Resource Development Council

RDC Comment Letter:
Support of the Two Bull Ridge Mine Permit #S-0606

March 1, 2013

Russell Kirkham
Manager, Coal Regulatory Program
Division of Mining, Land, and Water
550 West 7th Avenue, Suite 920
Anchorage, AK 99501

Via email to:

Re: Support of the Two Bull Ridge Mine Permit #S-0606

Dear Mr. Kirkham:

The Resource Development Council for Alaska (RDC) is writing to support approval of the permit revision application for coal mining activities at Two Bull Ridge Mine Permit #S-0606.

RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

Usibelli Coal Mine, Inc. (UCM) currently uses the Poker Flats Mine area for coal ash disposal, however, disposal in that area is being phased out. UCM has requested a revision to permit #S-0606 to allow for coal ash disposal at Two Bull Ridge.

UCM has used coal ash from Golden Valley Electric Association’s Healy 1 Power Plant at Poker Flats Mine for mine reclamation since the 1980s. UCM has monitored the down gradient groundwater during the entire operation period and there has been no indication of an increase in concentration of any constituents. The Two Bull Ridge Mine is the same geologic formation as the Poker Flats Mine, and thus, should have no impacts to ground water. As the Poker Flats Mine ends its operational life, it is a logical progression to relocate the coal ash site to the Two Bull Ridge Mine.

While the application for this revision is still being evaluated to determine if it meets Alaska Surface Coal Mining Program requirements, RDC is encouraged it will. RDC supports surface mining activities in the area, and encourages approval of the revision to the permit to ensure no delay to the mine.

Usibelli has been mining coal in Healy since 1943 and has demonstrated a commitment to maintaining and improving the environment through its reclamation process at similar operations in the area. RDC believes that the aforementioned factors merit timely issuance of a revised permit to allow for coal ash disposal to the new area being mined, Two Bull Ridge.

Thank you for the opportunity to comment.

Resource Development Council for Alaska, Inc.