2015-09-24_REVISION - C1982056 (2)

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TWENTYMILE COAL, LLC - FOIDEL CREEK MINE PERMIT REVISION PR14-10 WOLF CREEK RESERVE DEVELOPMENT AND MINING TECHNICAL ADEQUACY RESPONSE 4 - 09/17/15 Rule 2.03.6 — Right of Entry Information 4. Page 2.05-3 indicates that Twentymile Coal, LLC (TC) is pursuing leasing the Federal coal with a Lease By Modification (LBM) for the inclusion of the Wolf Creek Seam in the Federal Coal Lease COC - 54608. The Division cannot approve a mine plan that includes mining in the Wolf Creek Seam within this area until the LBM has been approved. Should the LBM not be approved by the time all other PR - 10 adequacy issues have been resolved, TCC will have to request continued extension of the decision due date until the LBM is approved. a. TC's response: TC recognized and discussed this constraint with the CDRMS at the time the PR10 application was submitted. TC will monitor the status of the pending federal lease modification and coordinate with the CDRMS relative to extension of the decision date for the PR, and submittal of the lease documentation when it becomes available. b. Division's response: This item remains outstanding and will need to be addressed prior to the approval of PR 10. Rule 2.05.2; Operation Plan — Estimate Area for Life of Operations 10. Revised Page 2.05-3 and 2.01-4 indicates the permit area is 22,447 acres and 22,607 acres respectively. Revised page 2.01-4 appears to include the 160 additional permit acreage proposed with PR10. The Division's records indicate the current permit acreage for the site is 20,100 acres and with the approval of PR10, the permit acreage will be 20,260 acres. Based on the Division's files, it appears TC reduced the permit area with TR51 to 22,443 acres. TC requested to increase the permit area by 80 acres with TR81 for a total permit area of 22,530 acres. Subsequently, with Permit Renewal No. 6 (RN6), the permit area was cited to be 22,450 acres. In the most recent technical revision,TR83, the permit area was cited to be 22,450 acres. Please review the permit acreage and permitting history and verify that the permit acreage will be 22,607 acres with the approval of PR10. a. TC's response: The Permit Area acreage figure has been checked and updated for consistency. Revised copies of the referenced page accompany these responses for replacement in the PAP. b. Division's response: We spoke on the telephone on July 14, 2015 regarding how TC verified the 22,607 acres. Based on this conversation, TC's draftsman calculated this area based on the permit boundary depicted on the mining plan map #23. The original adequacy question indicated that TC requested to change the permit area by 80 acres with TR81, this was incorrect. It appears TC requested to increase the permit area by 80 acres with TR82. Based on the Division's decision form for TR82, the Division approved an increase of 160 acres. It is unclear why there is a discrepancy in how many acres TC requested to increase their permit area by and how many acres the Division ended up approving. Given this, I compared the permit boundaries depicted on Map 23 approved with TR82 and the map that was previously approved prior to TR82 which appears to have been revised with TR78. It appears the permit boundary was modified in two areas based on these maps. One area is located in the NE 1/4 of Section 34 of T5N, R87W. The second parcel is located in the NE'/4 of Section 13 of T5N, R87W. A map depicting these two areas is enclosed to assist with this review. Does the 22,607 acre total permit area projected with PR10 include these parcels? c. TC's response: The PR14-10 submittal did not include Map 23 (relevant map showing the Wolf Creek Mining area was labeled Map 23 in the original submittal, but was corrected to Map WC23, since Map 23 shows the entire Twentymile Mining Area). The most recent update to Map 23 was for TR13-83 (map revision identified as 01/24/14). This map includes the two