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Twentymile Coal, LLC. <br />Page 3 <br />September 4, 2015 <br />revised page 2.014 is prior to the date TR33 was submitted. TR33 did not update page <br />2.01-4 so it is likely the 23,040.9 acres from PR5 does not include the 7.2 acre addition <br />from TR33. By adding the 7.2 acres, the total permit area should have been 23,048.1 <br />acres with the approval of PR5. The Division's decision form does not appear to have <br />been updated with the correct permit area when RN3/PR5 was approved. PR6 requested <br />to increase the permit area by 560 acres. This revision was approved but it does not <br />appear the Division's decision form accounted for the increase in acreage. With the <br />approval with PR6, the permit area should have been 23,608.1 acres (23,048.1 + 560 <br />acres). Then, TR51 reduced the permit acreage by 1,320 acres. During the review of <br />TR51, the permittee submitted MR205 which should not have changed the permit <br />acreage. When the Division approved MR205, the decision form indicated a permit area <br />that was 1,320 acres less than the previously approved permit area. Subsequently the <br />Division approved TR51 and reduced the permit area again by 1,320 acres. Given this, it <br />appears the 1,320 acres was inadvertently reduced twice from the Division's records. <br />When TR51 was approved, the permit acreage should have been 22,288.1 acres. <br />Subsequently, with TR82, the Division approved a 160 acre increase in the permit <br />boundary yielding a permit area of 22,448.1 acres (22,288.1 + 160 acres). PR10 requests <br />an approval of a 160 acre increase in the permit area. By adding 160 acres to 22,448.1 <br />acres, the total permit area should be about 22,608.1 acres. PR10 indicates the permit <br />area should be 22,607 acres. The 1.1 difference in acreage is likely due to a rounding <br />error. The Division will fix the discrepancy in our records. <br />Also, the Permit Renewal No. 6 (RN6) application listed the mineral and surface <br />ownership acreage by ownership (Federal, State and Private acreage). The table below <br />depicts this information. <br />RN6 <br />Application <br />Federal <br />State <br />Private <br />Private <br />PR10+ <br />TOTAL <br />Surface <br />6070 <br />7613 <br />8767 <br />160 <br />22610 <br />Mineral <br />8478 <br />7758 <br />6214 <br />160 <br />22610 <br />There is a discrepancy of three acres between what TC indicates the permit area should <br />be and what the sum of the ownership acres yields. Please review the ownership acreage <br />(both surface and mineral) and update the information so that the total ownership acreage <br />equals the 22,607 acre permit area. <br />