2014-10-01_REVISION - C1981044 (2)

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MOFFAT COUNTY MINING, LLC - WILLIAMS FORK MINES TECHNICAL REVISION TR14 -36 TEHNICAL ADEQUACY RESPONSES The Colorado Division of Reclamation, Mining and Safety received your response to the Division's first adequacy review for TR36 on July 16, 2014. There are several items that will need to be addressed prior to the approval of TR36. The Division attempted to maintain the format of the previously submitted adequacy review letter with the initial adequacy items listed followed by MCM response to these items. If additional adequacy issues were identified they are listed as a DRMS response. The initial Permit Renewal No. 6 adequacy item responses that were considered resolved during the first review of TR36 were deleted from this letter for clarity and to simply the review. For several items, Moffat County Mining (MCM) responded to several items with one response at the end of the section. The Division's response to these items follows MCM response. Rule 2.03.4 — Identification of Interests 2) Please update Exhibit 42 — Ownership and Control Information a. MCM Response: Updated ownership and control information (current as of 02/14) accompanies these responses for replacement in Exhibit 42. b. DRMS Response: The first page of the currently approved Exhibit 42 is the organization chart for MCM and its parent companies. A revised organization chart was not submitted. The Division assumes MCM wishes to leave this diagram in the Exhibit. If so, please indicate this, or provide revised diagrams. Otherwise, the revised tables submitted for Exhibit 42 are adequate at this time. 3) Revised Pages 2.03 -8 to 2.03 -11 contain updated surface and coal ownership information. All surface owners of record within and immediately adjacent to the permit area are shown on Map 1. All Coal owners of record within and adjacent to the permit area are shown on Map 2. Map 1 and Map 2 have not been revised. Please review these maps and submit revised copies if necessary with updated information. a. MCM Response to items 2 and 3: The current corporate organization chart is included with these responses. Maps l and 2 have been updated to reflect current surface and mineral ownership, consistent with the text ownership listing. b. DRMS Response: i. Item No. 2 above is resolved. ii. Item No. 3: The following entities are listed on revised pages 2.03 -8 and 9, but are not depicted on the Surface Ownership Map #1: Axial Basin Ranch Co., Colorado Department of Transportation, Lorence Ellgen, Moffat Limestone Company, John & Steve Raftopoulus, and Elof Wheeler. Also, the following entities are depicted on Map #1 but are not listed on revised paged 2.03 -8 and 9. Colowyo Coal Co., L.P. and K & P Musgrave. onse: The initial ownership listing on page13 -o urface and CA wnership ". Axial Basin Ranch Co. and Colowyo Coal Company.-T.P. are two entitie7 under the same corporate ownership — generally, surface ownership and water are held under Axial Basin, while mineral ownership is shown under Colowyo. The text listing and map designations have been modified to reflect this. State Highway 13 is owned by the State of Colorado, and managed by the Colorado Department of Transportation (CDOT).