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Savage and Savage Environmental <br />practical solutions for environmental issues <br />4610 Haystack Drive 970 674 8080 telephone <br />Windsor, Colorado 80550 970 6748088 facsimile <br />oavageandoavagega earthlink.net <br />March 30, 2015 <br />14T-07 e -WI-05 <br />RECEIVED <br />Terry Ireland MR 0 6 2015 <br />U.S. Fish and Wildlife Service <br />445 West Gunnison Avenue, Suite 240 P�gangq Field fltFoe <br />DWis or, of Reclamation, <br />J <br />Grand unction, Colorado 81501 -5711 1v;' ;;ng and Safety <br />RE: Concurrence Request for Threatened and Endangered Species Clearance ( CDRMS <br />Mid -Term Review) — GCC Energy Ding II Mine, La Plata County, Colorado <br />Dear Mr. Ireland: <br />GCC Energy, LLC (GCC) operates the King II Mine which is an underground room and <br />pillar coal mine located about seven miles southwest of Hesperus in La Plata County, <br />Colorado. Surface facilities of the King II Mine are located within Section 36, Township <br />35N, Range 12W of the New Mexico Prime Meridian in La Plata County. Underground <br />workings are located within Sections 19, 20, and 30, Township 35N, Range 11W; and <br />Sections 24, 25, 26, and 35, Township 35N, Range 12W; all of the New Mexico Prime <br />Meridian. <br />GCC currently holds mining and reclamation permit C -1981 -035, issued by the Colorado <br />Division of Reclamation, Miming and Safety ( CDRMS). CDRMS is currently conducting <br />a mandated regular mid -term review of the GCC King II Mine permit and has requested <br />that GCC update the approved permit text to reflect any changes to information regarding <br />threatened and endangered species (T &E) so that CDRMS can affirmatively find that, <br />"the [mining and reclamation] activities will not affect the continued existence of <br />endangered or threatened species or result in the destruction or adverse modification of <br />their critical habitats. " <br />Prior to the permitting of the operation in 2005 -2006, we obtained clearance for <br />threatened and endangered species, and critical habitat from USFWS (USFWS to <br />OSMRE letter of March 3, 2006). After completion of surface facilities construction, <br />subsequent development at the King II Mine has been soley related to underground <br />mining, entailing additions to coal reserves for mining, with no additional surface <br />disturbance. An additional T &E species survey and concurrence was undertaken in 2014 <br />for future surface exploration drilling in the area by GCC. No potential impacts to T &E <br />species were identified for that project. I am currently preparing an Environmental <br />