2015-05-18_REVISION - C1980007 (2)

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W00Ae-A Mountain Coal Company May 18, 2015 Mr. James R. Stark Colorado Department of Natural Resources Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, CO 80203 Mountain Coal Company, LLC West Elk Mine P.O. Box 591 Somerset, CO 81434 Jessica A. Loveland, P.E. EnvironmenW Engineer iloveland(a?archcoal.com phone: 970.929.2308 Re: Mountain Coal Company, LLC, West Elk Mine; Permit No. CO -80 -007; Request for Phase I Bond Release of Mine Ventilation Borehole Pads and Roads in the Dry Fork of Minnesota Creek Area Dear Mr. Stark. Please find enclosed Mountain Coal Company, LLC's (MCC) application for a Phase I Bond Release. At this time, the following application does not include proof of publication of the public notice or return receipts for the delivery of the landowner letters. These will be sent subsequent to MCC receiving them. MCC requests Phase I Bond Release of $110,452.20 for mine ventilation borehole (MVB) sites and roads that have been reclaimed within the Dry Pork of Minnesota Creek area (see Table I & II). These sites are located on National Forest System lands within portions of Sections 33 and 34 of Township 13 South, Range 90 West and Section 2 of Township 14 South, Range 90 West. These sites and roads were necessary for temporary mine ventilation. MCC's mining and reclamation permit was originally issued by the CDRMS in July 1981, and was reissued August 1986, January 1993 (effective August 1991), July 1996, July 2001, July 2006 and July 2011. The current five -year permit term expires July 31, 2016. MCC's five -year permit area contains lands in Sections 9- 11, 13 -36, T13S, R90W, 6th PM; and Sections 23 -26, T13S, R91W, 6th PM, and Sections 1 -5 , 8 -12, T14S, R90W, 6th PM in Delta and Gunnison Counties. The Iocation of the lands can be found on the USGS 7.5 minute Somerset and Minnesota Pass quadrangle topographic maps. The current permit area encompasses approximately 17,154.9 acres. MCC holds reclamation surety bonds from Arch Insurance Company and Bond Safeguard insurance Company (Bond numbers SU1116159 and 5010562, respectively) totaling $15 million. The reclamation cost estimates for the reclaimed sites that are part of this request are covered by these bonds. Reclamation of the various site locations and roads within MCC's permit was completed in 2014. This included the plugging and abandonment of nineteen boreholes, as well as backfilling and regrading their associated drill pad locations and access roads. The sites and roads proposed for bond release have been revegetated and stabilized using various methods of seeding, fertilizing, mulching and instaIlation/application of straw mulch erosion control blankets. Approximately 10.05 acres have received these treatments. As agreed to in email correspondence dated January 25, 2011 (See Appendix IT), MCC's Reclamation Photograph Reports of the reclaimed MVB sites and associated roads are sufficient for documenting that all facilities have been removed from each site and the sites have been regraded to approximate original contour. Therefore, drawings showing cross - sections of the backfilled and graded areas, drainage control facilities and the as -built reclamation have not been submitted with this request. The Reclamation Photograph Report (initiated in 2004) has been an annual documentation project that MCC voluntarily performs. It demonstrates and documents qualitative reclamation success over time. In addition to the Page 1 of 2