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Twentymile Coal, LLC (TC) <br />Narrative <br />Lease by Modification Application Wolf Creek Reserve — April 2014 <br />coal. On an overall basis, approximately 85-90 percent of the yearly production will be from the <br />longwall mining method. The remaining 10-15 percent will be from continuous miner mains <br />and gate road development. <br />4. Unsuitability Criteria <br />Subpart 346 1. 1 of 43 CFR established criteria that must be utilized to determine if the proposed <br />area can be offered for lease. TC has reviewed this subpart and, based on detailed review, <br />submits that the proposed lease modification would satisfy Criterion 2 and 3 (43CFR <br />3461.5(b)(1) and (c)(1). These criteria do, however, provide an exception procedure under 43 <br />CFR 3461.5(b)(2)(i) and (iv), and 43 CFR 3461.5(c)(iii) and (iv) respectively. It is TC's <br />intention that the exception criteria be applied to the proposed leasing activity. <br />In reference to Criterion 3, TM understands that a public notice procedure will have to be <br />followed and completed prior to issuance of this lease modification. <br />WCR BLM Lease App Narrative 0414.docx Page 16 <br />