2015-10-26_REVISION - C1981035

• Permit No: C1981035
• IBM Index Class Name: Revision
• Doc Date: 10/26/2015
• Doc Name: Adequacy Review #2
• From: DRMS
• To: GCC Energy, LLC
• Type & Sequence: TR24
• Email Name: RAR
• Email Name: DIH
• Media Type: D
• Archive: No

King Coal Mine (C-1981-035) TR-24 Adequacy Review #3 Response
on 10 July 2015. DRMS sent adequacy questions to GCC on 4 September 2015 and these
are in the process of being answered. DRMS received GCCs adequacy responses on 21
October 2015. Decision due date is 30 November 2015.

3. Rule 2.05.3(5) Topsoil
b. DRMS 02/18:
The narrative in King II Section 2.05.3 page 6 states that the topsoil
replacement depth will be 6 inches. The narrative in King II Section 2.05.4 page 9 states
that the topsoil finished depth will be 12 inches. Please clarify what the final replacement
depth of topsoil will be and verify that enough topsoil has been salvaged to achieve the
required depth.

DRMS 06/14:
The permit has been revised, as requested. However, the content of revised
page 6 differs somewhat from the version currently approved. Please review the approved
verbiage
and page breaks to ensure that no information is lost.

The page breaks on revised King II Section 2.05.3 have been revised to match the currently
approved version. Please replace 2.05.3 pages dated April 30, 2015 with attached 2.05.3 pages.
This item has been satisfactorily addressed.

2.05.6 Mitigation of Impacts of Mining Operations
1. DRMS 02/18:
Rule(s) 2.05.6(2)(a)-(c), 4.04(1)(a), and 4.18- Based on the
requirements of Rule 2.05.6(2)(a)-(c), C-1981-035 is required to contain a fish and wildlife
plan consistent with Rule 4.18. Based on the information presented in Appendix 8 of C-
1981-035, provided by both the USFWS and the CPW, due to the small size of the overall
disturbance area the potential impacts to wildlife are minimal. However, Appendix 8 also
includes a list of species that are found in La Plata County and which may occur within the
permit area; as such there is no specific fish and wildlife plan in accordance with
2.05.6(2)(a)-(c) which specifically discusses how the plan will minimize disturbances and
adverse impacts on fish and wildlife and related environmental values during mining and
reclamation operations found or potentially found within the permit and adjacent areas.

DRMS 02/18
a.: Please submit a fish and wildlife plan consistent with Rule 4.18 based
on the determination that there will be impacts to fish and wildlife.
This item has been satisfactorily addressed.

DRMS 02/18
b. : If an update to the information to include new or added T&E species,
and discussion of potential impacts to current State and Federal Threatened and
Endangered plant and animal species lists, shows that the plan will require compliance
with Rule 2.05.6(2)(a)(iii)(A) and (B), please include the information with the plan.

DRMS 06/14
: Section 2.05.6 has not yet been updated. Please revise in accordance with
4.18.

An updated Fish & Wildlife Plan has been included in King I Section 2.04.11 and King II Section
2.05.6
.
These items has been satisfactorily addressed with the exception of:
Prepared by: R. Reilley October 2015
File location: M:\\Coal\\rar\\1MKingCoal\\TR24_MidTermReview Page 6