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��Am Mountain Coal Company September 04, 2014 Mr. James R. Stark Colorado Division of Reclamation, Mining and Safety Office of Mined Land Reclamation 1313 Sherman Street, Room 215 Denver, Colorado 80203 Mountain Coal Company, LLC West Elk Mine P.O. Box 591 Somerset, CO 81434 Kathleen G. Welt Environmental Engineer III kwelt(a)archcoal.com phone: 970 929.2238 Re: Mountain Coal Company, LLC, West Elk Mine; Permit No. C -1980 -007; Minor Revision No. MR -407: Mid -term Review MT -07 Responses Dear Mr. Stark: Mountain Coal Company, LLC (MCC) submits this letter, the attached application form, and other attachments as detailed in the responses to the Division's Mid -term review presented below. The Division's question is in italics and is followed by MCC's response. Rule 2.03.4 — Identification of Interests West Elk updated Exhibit 1 — Officers and Directors, with Minor Revision 398, which was approved on 1 November 2013. Please review the information contained in Exhibit 1 and update as necessary. There have been no further changes to the MCC, AWBG or AWR Officers and Directors lists since those made with MR -398. A few updates were needed to the Arch Western Acquisition Corporation, Ark Land Company and Arch Coal, Inc. lists and revised lists for Exhibit 1 are attached. A summary of the changes is included with the new lists. Rule 2.03. 10 — Identification of Other Licenses and Permits 2. During the Division's quarterly records check on complete inspections it has been noted the West Elk Mine's CDPS permit expired in 2009. There is a letter in the file that West Elk is currently operating under administrative extension until a new permit is issued. Please provide the Division with a discussion on the status of the mine's CDPS permit. MCC was last contacted in February of this year by the CDPHE- WQCD Environmental Protection Specialist working on MCC's CDPS permit. At that time she predicted that the public notice of the draft permit would be published in March, but was not. There has been no further contact by WQCD since that time, so the administrative extension continues. Rule 2.04. 10 — Vegetation Information 3. Pursuant to Rule 2.04.10(5), please review the Delta and Gunnison County threatened and endangered plant species lists and update this section if necessary. If there are any new listed species, a new on the ground survey will be required. MCC contracted with a biologist with Barr Engineering to conduct an updated evaluation of T &E plant and wildlife species that could occur on or near the West Elk Mine site. A copy of the report is attached. The evaluation determined that the likelihood of onsite occurrence of federally - listed plant species ranged from "unlikely" to "no likelihood ".