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A>/ <br />W3 cowc ny Seneca Coal Company <br />October 10, 2013 <br />Ms. Janet Binns <br />Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80202 <br />RE: Seneca II -W Mine (Permit C -82 -457) <br />TR -81, Bond Reduction Request <br />Adequacy Comment Response <br />Ms. Binns, <br />Seneca Coal Company (SCC) is submitting this Adequacy Response to Technical Revision No. <br />81 (TR -81) in response to your e-mail comment dated October 10, 2013. <br />Comment 1 <br />I have reviewed TR81 for completeness. Unfortunately, you did not include any revised <br />pages. I understand that you had submitted the updated reclamation cost estimate with <br />MR77. Jared is completing that permitting action. We believe that it would be more <br />appropriate to remove the June 2013RCE from MR77, and submit it as TR81. This would <br />meet the requirement for Rule 3.02.2(5) to `provide evidence" warranting reduction of the <br />bond amount <br />Response: The Division calculated a new reclamation cost estimate taking into account the <br />remaining tasks to be completed that have not been released through the phased bond release <br />process and the tasks removed due to approval of PRb. MR77, Midterm Adequacy Review and <br />Request for Revision, required SCC to submit the entire June 2013 RCE for insertion into the <br />PAP. This was submitted on October I" as part of the adequacy response and included the <br />summary (15 pages) and the detailed calculation sheets (121 pages). <br />Per our phone conversation on Thursday 10110113, SCC is submitting the 15 page summary of <br />the RCE, rather than recopying and resubmitting the entire 134 pages of summary and details <br />and references TAB 25, Bonding, for the entire June 2013 Reclamation Bond Estimate (as <br />submitted for approval on October 1, 2013). The entire June 2013 RCE is available on request <br />and will be an integral part of the permit upon the upcoming approval of MR77. <br />Seneca Coal Company . P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276 -5217 • FAX (970) 276 -5222 <br />