2015-09-24_REVISION - C1982056 (2)

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permit boundary modifications noted in the comment above. The Permit Area was noted in TR13-83 (both pages 2.01-4 and 2.05-3) as 21,447 acres. With the addition of 160 acres for PR14-10 in Sections 12 and 13 (TSN, R86W), the total Permit Area acreage should be 22,607. d. Division's response: Upon further review, the large difference in permit acreage the Division has been recording and what Twentymile Coal has determined seems to have originated with Permit Renewal Application No. 3 (RN3), Permit Revision No. 5 (PR5) and subsequent revisions. It appears the Division requested the permittee to clarify the permit acreage with RN3 and there was a decision made on what the permit area should be. However, I cannot determine for certain what the final decision was based on the information in the Division's file for RN3. But, PR5 and RN3 were under review at about the same time period and PR5 was approved two months after RN3 was approved. When PR5 was approved, permit page 2.01-4 was updated with a revised permit area of 23,040.9 acres. Technical Revision No. 33 (TR33) was submitted during the review of PR5 and was approved prior to PR5 and added 7.2 acres to the permit area. The date on revised page 2.01-4 is prior to the date TR33 was submitted. TR33 did not update page 2.01-4 so it is likely the 23,040.9 acres from PR5 does not include the 7.2 acre addition from TR33. By adding the 7.2 acres, the total permit area should have been 23,048.1 acres with the approval of PR5. The Division's decision form does not appear to have been updated with the correct permit area when RN3/PR5 was approved. PR6 requested to increase the permit area by 560 acres. This revision was approved but it does not appear the Division's decision form accounted for the increase in acreage. With the approval with PR6, the permit area should have been 23,608.1 acres (23,048.1 + 560 acres). Then, TR51 reduced the permit acreage by 1,320 acres. During the review of TR51, the permittee submitted MR205 which should not have changed the permit acreage. When the Division approved MR205, the decision form indicated a permit area that was 1,320 acres less than the previously approved permit area. Subsequently the Division approved TR51 and reduced the permit area again by 1,320 acres. Given this, it appears the 1,320 acres was inadvertently reduced twice from the Division's records. When TR51 was approved, the permit acreage should have been 22,288.1 acres. Subsequently, with TR82, the Division approved a 160 acre increase in the permit boundary yielding a permit area of 22,448.1 acres (22,288.1 + 160 acres). PR10 requests an approval of a 160 acre increase in the permit area. By adding 160 acres to 22,448.1 acres, the total permit area should be about 22,608.1 acres. PR10 indicates the permit area should be 22,607 acres. The 1.1 difference in acreage is likely due to a rounding error. The Division will fix the discrepancy in our records. Also, the Permit Renewal No. 6 (RN6) application listed the mineral and surface ownership acreage by ownership (Federal, State and Private acreage). The table below depicts this information. RN6 Application Federal State Private Private PR10+ TOTAL Surface 6070 7613 8767 160 22610 Mineral 8478 7758 6214 160 22610 There is a discrepancy of three acres between what TC indicates the permit area should be and what the sum of the ownership acres yields. Please review the ownership acreage (both surface and mineral) and update the information so that the total ownership acreage equals the 22,607 acre permit area. e. TC's response: As a practical matter, when dealing with the Permit Area and ownership acreages, because the numbers are relatively large, TC has always rounded to the nearest whole acre, a practice which has been accepted by the Division. The referenced difference between the ownership acreage provided in the Permit Renewal application and the cumulative acreage carried forward for the Permit Area reflects this rounding convention, is negligible given its relative magnitude (3 acres/22607 acres = 0.000133, or 0.0132%), and does not require