Minimum work obligations under "Licence" for coal exploration may cover the following work components:

1) Topographical survey of the licensed area; 2) Seismic survey covering the licensed area; 3) Exploration drilling covering the coal basin area; 4) Hydrogeological testing of the boreholes; 5) Pump tests of the boreholes; 6) Geological logging, Geo-physical logging of the boreholes and core recovery; 7) Chemical analysis of coal samples and Geo-Technical information of rock; 8) Proper and effective sealing of the boreholes on completion of drilling and other tests.

9) Initial Environmental Examinations (IEE) and Environmental Impact Assessment (EIA) due to coal exploration work i.e. seismic survey and drilling.

After above field work for coal exploration the licensee should recommend the minimum following information in their "Exploration Report" for the consideration of Bureau of Mineral Development (BMD): 1) In-situ geological coal reserve in the coal basin; 2) Measured or proven coal reserve and measured or proven area of the coal basin; 3) Indicated or probable coal reserve and indicated or probable coal basin area; 4) Mineable coal reserve; 5) Outline of the mine plan; 6) Outline of the mining methods; 7) Probable list of equipment and materials for mining; 8) Financial analysis of mining the coal reserve; 9) IEE/EIA report on coal exploration.

Scope of works or minimum work obligations under "Lease" for coal mine development and operation may cover the following work component: There are two parts of work under "Mining Lease" (a) Mine Construction and Development, (b) Mine Operation and Maintenance, which contain:

Mine Construction and Development: 1) Initial Environmental Impact Assessment (EIA) due to mine development and operation; 2) Initial Social Impact Assessment (SIA) of leased area; 3) Rehabilitation and resettlement issues in the leased area; 4) Mine design and planning; 5) Detail EIA and SIA of the leased area. [It may be mentioned here that EIA and SIA of the leased area can be done effectively and judiciously only after the design of the mine and the mine plan. After completion of the mine design and mine plan a clear and vivid picture of geology and geo-technical issues of the underground mine or surface mine can be assessed and EIA and SIA can be conducted accordingly]; 6) Shaft sinking; 7) Pit-bottom development, roadway development, coal face development, etc.; 8) Subsidence effect.

Mine Operation and Maintenance: 1) Coal extraction technology from coalface; 2) Strata control, roof control, water control; 3) Coal transportation system from mine to power plant; 4) Mitigation plan of environmental impacts; 5) Mine Environmental Management Plan (EMP); 6) Mine ventilation and safety; 7) Control of air-borne coal dust and spontaneous combustion; 8) Components of mine rescue team and duties and responsibilities of the rescue team; 9) Emergency Response Plan (ERP).

It is very important to specify the above minimum work programme under "Exploration License" and "Mining Lease" in the draft coal policy. Details of these work obligations under "Exploration Licence" and "Mining Lease" and findings from Exploration Licence may be described under existing Bangladesh Mines and Mineral Rules. Present Mines and Minerals Rules do not contain those.

Specific condition for an applicant of "Mining Lease": An applicant for mining lease should complete the coal exploration work under exploration license before applying for mining lease. Or, in other words, provision may be made in the coal policy for a mining leasee to undertake the coal exploration work during the first three years (maximum) of mining lease. After acceptance the coal exploration work by Bureau of Mineral Development (BMD) the leasee can start work under mining licence. It means that work under exploration licence and submission of coal exploration report to BMD is obligatory for undertaking work under mining lease. The above points may be considered for incorporation in the draft coal policy.

Amendment of Clause 2.2 (GA) and Annexure-KA of reserve table: In the clause 2.2(GA) of the latest draft coal policy it has been mentioned that 60 million tons of coal can be extracted from both Dighipara and Khalashpir underground coalmines. But the techno-economic feasibility report on Khalashpir coal deposit submitted to BMD on August 23, 2006 reveals proven reserve of 297.57 million tons in three seams and a total reserve of 523.49 million tons spreading in eight coal seams covering an area of 7.5 sq. km. This is the outcome of high resolution of 2D and 3D seismic survey over an area of 12.25 sq. km. and drilling of 17 boreholes (14 holes by Hosaf and 3 holes by GSB) at Khalashpir coal basin. In the Khalashpir coal feasibility report it has been further shown that 92.20 million tons of coal could be produced from seam I, II and IV during 30 years. The rest of the coal can be produced in future as per requirement of the country. Accordingly the Clause 2.2(GA) and Annexure-KA need to be amended.

Reserve of peat coal: Peat coal has been discovered in Khulna, Faridpur and Madaripur in 1957. A study made by UNDP in 1983-84 revealed the existence of 400 million tons of peat coal in different areas of Bangladesh. Petrobangla under a study with the assistance of CIDA in 1986 discovered 61.27 million tons of proven reserve of peat coal in Dakatia and Kala Mouza in Khulna and Chanda-Baghia area in Madaripur at a depth ranging from 2.0m to 4.0m from surface. Since it is near surface deposit 55.00 million tons of peat coal can be extracted considering as 90 per cent recovery. Though the heating value of peat coal is about 6,370 Btu/lb and moisture content is very high (70% to 80%), these peat coals can be used in small-scale power plants (10-20MW) and brickfields. The above findings may be reflected in the respective clauses and tables of the draft coal policy since reserve of peat coal has not been shown in the reserve table under Annexure-KA.

Clause 3.4.3 (coal briquette): Preparation of briquette should be done from peat coal only.

Coal bed methane: No study about the contents/assessment of coal bed methane has been done in any coalfields of Bangladesh. Therefore contents of methane is to be assessed first before undertaking any programme for the extraction of coal bed methane. This type of study may be conducted in Jamalganj coalfield. Great depth, high temperature, high-grade coal, high thickness of coal seams are some of the features for finding coal bed methane. Jamalganj coal field has got all these potentialities. This may be incorporated in the respective clauses of draft coal policy.

The findings and conclusions of the above observations are for the consideration of the appropriate authority responsible for finalisation of draft Bangladesh Coal Policy.

Engr A K M Shamsuddin is a mining engineer and former Managing Director, Pashchimanchal Gas Co Ltd (PGCL), E-mail: sham19472001@yahoo.com