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December 22, 2014 <br />ToC m Bird Sent via email to tbird acc.com <br />Manager of Coal Services <br />Environmental Services GCC Energy, LLC <br />6473 County Road 120 <br />Hesperus, CO 81326 <br />Environmental Chemistry RE: Review of Annual Hydrology Report <br />Dear Mr. Bird, <br />Site Sampling A Testing As per your request, Dr. Joe Bowden of our office reviewed <br />the water sampling data from both the King I and the King II <br />mines monitoring wells /sites. This review is to address any <br />Site Assessments trends and /or areas of concern, which are evident from an <br />analysis /interpretation of the presented data. <br />Our new office is located at 801 Perins Canyon Drive - Our local phone is still 247 -0132 <br />The data submitted to the State of Colorado, Division of <br />Strategic Planning <br />Reclamation, Mining and Safety was reviewed to determine any <br />trends. In most cases, the trends are represented by analytical <br />values with high degrees of variability from quarter to quarter and <br />Soil A Geochemistry <br />year to year. The paradox found in this data is that most of the <br />trends are flat and in many cases exhibiting large standard <br />deviations. Nevertheless, it is our professional opinion that many <br />Safety Assessments <br />of the trends are real and are discussed below. <br />As to the question are these trends a result of the mining <br />µ <br />activities at either King I or King II, it is again our professional <br />Contract Research <br />opinion that these trends are not a result of mining activities at <br />either King I or King II mines. The single constant observation <br />over the monitoring cycles is a very high degree of analytical <br />Wetland Remediation <br />variability which tends to follow the dry/wet cycles of precipitation <br />observed in Southwest Colorado. Some of these cycles are <br />profound in their degree of variability. For example, the water <br />Reclamation Services <br />levels measured in the King 11 Down - gradient monitoring well <br />varied from near artesian [2 inches below top of well] to a depth of <br />more than 110 inches below top of well. <br />... ...........................•••• <br />The southwest setting of these mines are at the interface of two <br />regional environs, the northern edge of the high desert /pinon- <br />P . o . B o x 4 1 2 4 <br />juniper ecosystems, and southern edge of the low alpine /Gambel <br />Durango, co 81302 <br />Oak - Ponderosa Pine zone. This interface is noted for <br />1. 8 0 0. 5 5 3 6 2 6 6 <br />unpredictable precipitation events, driven by decade long regional <br />warming and cooling cycles. For example, the annual rainfall for <br />cdsenviroWfrontier.net <br />three nearby towns, demonstrate this unpredictable nature. <br />... ............................... <br />Durango, CO has a ten -year average rainfall of around 21 inches, <br />Cortez, CO comes in at around 12 inches, while Farmington, NM <br />is only about 9 inches. <br />Our new office is located at 801 Perins Canyon Drive - Our local phone is still 247 -0132 <br />