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Colorado <br />Planning Department <br />1060 East 2nd Ave <br />Durango, CO 81301 <br />(970)382-6263 <br />November 11, 2015 <br />Robin Reilley <br />Mined Land Reclamation Board <br />Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />via email to robin.reilley@state.co.us <br />RE: King Coal Mine (C-1981-035) Technical Revision No. 26 (TR -26) <br />Dear Ms. Reilley: <br />Thank you for notification and the opportunity to provide comment on the King Coal Mine Technical Revision <br />No. 26. We are happy to see that additional groundwater monitoring wells will be installed. <br />Specific to TR -26, we note that beyond locations, our primary concern with groundwater monitoring wells is <br />that it tests for the full range of constituents relevant to coal production as required by State regulation. We <br />understand GCC has had concerns with testing for the full range of constituents associated with coal mining as <br />some constituents may be associated with background conditions rather than directly related to the mine <br />itself. The data potentially related to coal influence, however, still needs to be collected. If contaminants of <br />concern are identified and believed to be background rather than directly associated with the mine, then this <br />may be documented, but please assure that the essential parameters are used in the data collection. <br />Above all else, La Plata County notes that GCC does not have a local permit to operate. GCC was notified in <br />2010 of the need for a county land use permit, but neither key permit materials nor mitigations are in place. <br />Thus, we question whether any activities permitted by the State since 2010 should be occurring until the local <br />permit is obtained. <br />Thank you again for the opportunity to comment. <br />Sincerely, <br />Victoria Schmitt, PE <br />La Plata County Planning Engineer <br />Cc: Joe Kerby, County Manager <br />Damian Peduto, Community Development Director <br />Daniel Murray, Senior Planner <br />Sheryl Rogers, County Attorney <br />