2015-11-30_REVISION - C1982056 (3)

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COLORADO Division of Reclamation, Mining( and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 November 30, 2015 Jerry Nettleton Twentymile Coal, LLC. 29515 Routt County Road 27 Oak Creek, CO 80467 RE: Twentymile Coal, LLC- Foidel Creek Mine; C-1982-056 13 -Left Outby Utility Borehole Cultural Resource Survey MR292, Adequacy Review Dear Mr. Nettleton, The Division has reviewed the above referenced revision. The following items will need to be addressed prior to the Division's approval of the revision: 1.) Revised page 2.04-9.1 indicate the results of the proposed cultural resource survey for the 13 -Left Outby Utility Borehole proposed with this revision are known and reads as if the survey has been completed. This is not the case. Please revise page 2.04-9.1 to separate out the discussion for the 13LT Outby Utility Borehole under a different subsection. MR292 is seeking approval of a plan to conduct a cultural resources survey. Given this, the results of the cultural resource survey for this area is unknown, it cannot be said that no buried cultural materials were found within the proposed survey area. Under the new subsection the plan for the cultural resource survey can be discussed briefly and a citation added that a detailed survey plan is included in Exhibit 6T. 2.) The proposed cultural resource survey inventory area needs to be clarified. With the submittal of MR292, the proposed work plan prepared by Metcalf Archaeology was included with an email from Twentymile Coal, LLC. (TC). that discusses several points of clarification. TC is proposing a 200 foot by 200 foot drill pad with MR291. The work plan indicates the drill pad area is 200 feet by 200 feet and Figure 2 of the work plan depicts a 200 foot by 200 foot pad with auger holes placed about 15 meter (about 50 feet) around the drill pad yielding a 300 foot by 300 foot inventory area. TC's e-mail indicates the maximum drill pad disturbance is 250 feet by 250 feet and should include a 100 foot buffer zone around the pad area yielding a 450 foot by 450 foot inventory area. Please revise the work plan to clarify the proposed inventory area. Once the survey has been completed and the results are known, the proposed revised pages submitted with MR291 can be updated and revised as necessary. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us John W. Hickentooper, Governor I Mike King, Executive Director I Virginia Brannon, Director