2015-06-10_REVISION - C1981035 (2)

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Page 2 June 10, 2015 King Coal Mine (C-1981-035) MT -07 Report Section 2.03.10 Under "zoning compliance", a La Plata County permit application is noted. La Plata County informed GCC of the requirement for a local land use permit in 2010, a submittal for a land use permit was received in 2012, and to date adequate information and mitigation has not been provided regarding haul traffic and water supply issues, amongst other items. For this reason, La Plata County has not been able to consider issuing a permit for this project. Nevertheless, the use continues to operate along a county road (CR 120), steadily increasing production traffic, which has come to dominate the county road putting residential travelers on the road at risk. Where pavement exists in the County Road, it is degraded. Where there is gravel, dust has been a significant problem to residents, and the County questions whether these dust impacts were considered in the State's air quality permit. We note that the air quality permit expired May 21, 2015. We hope the air quality permit renewal will take into account all air quality impacts, and we request information regarding the regulatory framework under which the mine will operate in the interim between the expired air quality permit and a renewal. We are interested in participating in the permit renewal. MT -07 Report Section 2.04.07 Observing that the conclusions with respect to hydrology as presented in the MT -07 Report are accompanied by minimal supporting data, we question the extent to which hydrologic impacts are understood. A primary question is regarding the consequences of removing vast areas of coal bed conduits on the hydrology of the area and the impact to the production of nearby wells. This does not appear to have yet been evaluated. Another question is regarding the possibility of nearby wells experiencing water quality impacts. Statements in the MT -07 Report make broad conclusions that there will be no impacts, and yet there does not appear to be data or analysis to substantiate this. We request that data addressing relevant constituents be gathered with resulting analysis and that review of that analysis be performed. With respect to water quality, it seems that periodic monitoring on relevant constituents would be required. We would like to see a specific water monitoring program that will extend into the future of the mine as extraction moves to new areas underground. Another item the MT -07 report does not address is the 20,000-40,000 gallons -per -day of water that is applied for operations within the mine. Having visited the mine, we understand that a large portion of this water is transported out of the mine on the coal. Given the hydraulic conductivity of the Menafee Formation, however, it is reasonable to question whether any water not removed from the mine on the coal may flow readily through the formation. This is a concern both with respect to water quality impacts and change of hydrologic conditions and historic well production in the area. Finally, the county has noted that GCC may not have sufficient water rights and reliable yield to meet their 20 acre-feet/year demand.