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Twentymile Coal, LLC. <br />Page 5 <br />September 4, 2015 <br />proposed under PR10. A brief summary of the proposed monitoring is provided for <br />inclusion in Exhibit 4. <br />b. Division's Response: <br />v. Site 900 appears to be upstream of the WCR affected area along Foidel Creek. <br />Given this, it would not serve as an appropriate downstream monitoring station <br />for Foidel Creek. Please revise the monitoring plan to monitor a site that is <br />downstream of the WCR affected area. <br />1. TC's response: As previously noted, site 900 now falls within the <br />eastern limits of the planned WCR mining area, however, exiting Site 29 <br />is outside the affected area, and would be suitable for collection of <br />information on any downstream water quality/quantity effects from the <br />proposed WCR mining activities. <br />2. Division's response: See item No. 7 above. The Division believes a <br />new surface water monitoring site should be established along Foidel <br />Creek upstream of the confluence of Middle Creek. Please revise this <br />page accordingly and update Exhibit 4E-11 and Exhibit 14 as necessary <br />to add this additional monitoring point. <br />Rule 2.04.4 - Cultural and Historic Resource Information and Rule 2.05.6(4) — Protection of Public <br />Parks and Historic Places <br />PR10 requests an increase in affected area of 150 acres. It was found during the review of PRI 1 <br />(Which mirrors the PR10 application except for it excludes mining in the area TC is currently <br />seeking a lease modification for in the coal lease COC -54608) that permit section 2.04.4 was not <br />proposed to be revised with updated information required by Rule 2.04.4. Given this, TC hired <br />Metcalf Archaeological Consultants, Inc. to conduct a Class III Cultural Resources Inventory for <br />the newly proposed affected area. The Division received the results of this inventory on August <br />21, 2015. These results have been forwarded to the State Historic Preservation Officer's office <br />(SHPO) for review and the Division is awaiting their response. The following items will need to <br />be addressed: <br />a. The PR10 application revised pages do not include updates to section 2.04.4 of the permit <br />to discuss the cultural resources inventory conducted for this project. Such language is <br />included in revised pages currently under review for MR289. It would be appropriate to <br />include the language currently proposed with MR289. For consistency, please revise this <br />section of the permit to discuss the cultural resources found within the proposed WCR <br />affected area. <br />b. According to the inventory, two sites; 5RT3324 and 5RT3325 are recommended to be <br />eligible for inclusion on the National Register of Historic Places (NRHP) and total <br />avoidance is recommended. These two sites are within the area that will be affected by <br />subsidence. It does not appear surface disturbance activities other than possible impacts <br />from subsidence will occur in these areas. TC, the Division and SHPO will need to <br />coordinate to determine if appropriate mitigation and treatment measures are necessary <br />