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Twentymile Coal, LLC. <br />Page 2 <br />September 4, 2015 <br />the permit area by 80 acres with TR81 for a total permit area of 22,530 acres. Subsequently, with <br />Permit Renewal No. 6 (RN6), the permit area was cited to be 22,450 acres. hi the most recent <br />technical revision,TR83, the permit area was cited to be 22,450 acres. Please review the permit <br />acreage and permitting history and verify that the permit acreage will be 22,607 acres with the <br />approval of PR10. <br />a. TC's response: The Permit Area acreage figure has been checked and updated for <br />consistency. Revised copies of the referenced page accompany these responses for <br />replacement in the PAP. <br />b. Division's response: We spoke on the telephone on July 14, 2015 regarding how TC <br />verified the 22,607 acres. Based on this conversation, TC's draftsman calculated this <br />area based on the permit boundary depicted on the mining plan map 423. The original <br />adequacy question indicated that TC requested to change the permit area by 80 acres with <br />TR81, this was incorrect. It appears TC requested to increase the permit area by 80 acres <br />with TR82. Based on the Division's decision form for TR82, the Division approved an <br />increase of 160 acres. It is unclear why there is a discrepancy in how many acres TC <br />requested to increase their permit area by and how many acres the Division ended up <br />approving. Given this, I compared the permit boundaries depicted on Map 23 approved <br />with TR82 and the map that was previously approved prior to TR82 which appears to <br />have been revised with TR78. It appears the permit boundary was modified in two areas <br />based on these maps. One area is located in the NE 1/4 of Section 34 of TSN, R87W. The <br />second parcel is located in the NE 1/4 of Section 13 of TSN, R87W. A map depicting <br />these two areas is enclosed to assist with this review. Does the 22,607 acre total permit <br />area projected with PR10 include these parcels? <br />c. TC's Response: The PR14-10 submittal did not include Map 23 (relevant map showing <br />the Wolf Creek Mining area was labeled Map 23 in the original submittal, but was <br />corrected to Map WC23, since Map 23 shows the entire Twentymile Mining Area). The <br />Most recent update to Map 23 was for TR13-83 (map revision identified as 01/24/14). <br />This map includes the two permit boundary modifications noted in the comment above. <br />The Permit Area was noted in TR13-83 (both pages 2.01-4 and 2.05-3) as 21,447 acres. <br />With the addition of 160 acres for PR14-10 in Sections 12 and 13 (TSN, R86W), the total <br />Permit Area acreage should be 22,607. <br />d. Division's Response: Upon further review, the large difference in permit acreage the <br />Division has been recording and what Twentymile Coal has determined seems to have <br />originated with Permit Renewal Application No. 3 (RN3), Permit Revision No. 5 (PR5) <br />and subsequent revisions. It appears the Division requested the permittee to clarify the <br />permit acreage with RN3 and there was a decision made on what the permit area should <br />be. However, I cannot determine for certain what the final decision was based on the <br />information in the Division's file for RN3. But, PR5 and RN3 were under review at <br />about the same time period and PR5 was approved two months after RN3 was approved. <br />When PR5 was approved, permit page 2.01-4 was updated with a revised permit area of <br />23,040.9 acres. Technical Revision No. 33 (TR33) was submitted during the review of <br />PR5 and was approved prior to PR5 and added 7.2 acres to the permit area. The date on <br />