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South Central Land & Mining LLC <br />1041 Field Street, Lakewood, Colorado 80215 -4831 <br />December 5, 2014 <br />ATTENTION: <br />Rob Zuber (rob.zuber @state.co.us), <br />Ginny Brannon (ginny.brannon @state.co.us) <br />Daniel Hernandez (daniel.hernandez @state.co.us) RECEIVED <br />Jeff Fugate (jeff.fugate @state. co. us) <br />Dave Berry (dave.berry @state.co.us) DEC 0 8 2014 <br />C/O Division of Reclamation, <br />Colorado Division of Reclamation, Mining and Safety Mining & Safety <br />1313 Sherman St Room 215 <br />Denver, CO 80203 <br />Dear Sirs: <br />As a partial property owner of 400 acres known as Southfield; our corporation, South Central Land <br />and Mining, LLC, objects to TR 43, EFCI's request to no longer monitor water. We also objected at <br />the Phase I Bond Hearing regarding the lack of monitoring wells in 2002. During the past 10 years <br />of reclamation EFCI has only full data on one monitored well, MW23. MW23 is the <br />upslope monitoring well 149 -170 feet into a coal seam and not into the ground water which we <br />believe to be at 350 feet. We base this on MWNW (formerly the North Well data from 1985 -1995) <br />and the downslope well (MW65) being monitored on Dr. Corley's property at 350 feet. <br />MW 10 (340 -402 feet next to the 40 acre refuse pile) was mined through in 2001. This monitoring <br />well had water consistently and was near a seepage area that produced water and that EFCI used <br />for dewatering the mine. <br />MW16, near the old Vento house, has been reported dry since December 2005. <br />EFCI hydrology consultants mention the dewatering of the mine numerous times in their <br />November, 2014 letter. Bishop, Brogden, and Rump prepared the inflow reports in 1986 Annual <br />Hydrology Report and reported 141.9 acre feet was removed from the North Well (MWNW). <br />Bishop, Brogden also stated in September 19, 2013 letter that the mine would not fill up for 120- <br />160 years or meet equilibrium. 4.05.12 120(2)(j)(IV) ensures the protection of the groundwater <br />recharge capability to be at pre- mining levels and not in 120 years. <br />The quantity of water that was removed from the mine (based on inflow reports and available <br />Hydrology Reports) by dewatering from 1985 -2000 was 150 million gallons of water. <br />