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rNR <br />c*o\! <br />January 13, 2016 <br />COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Naiwal Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Tonya Hammond <br />Snowcap Coal Company <br />P.O. Box 1430 <br />Palisade, CO 81526 <br />Re: Roadside Mine (Permit No. C-1981-041) <br />Technical Revision 67 (TR -67) <br />Adequacy Review Comments <br />Dear Ms. Hammond: <br />The Division of Reclamation Mining and Safety (Division) has completed its review of Technical Revision 67 <br />(TR -67) for Snowcap Coal Company's (SCC) Roadside North and South Mines. TR -67 was received by the <br />Division on December 4, 2016 and was deemed complete on December 14, 2015. <br />Snowcap Coal Company (SCC) is proposing to revise the permit boundary, along with the surface, mineral and <br />affected acreages to reflect the released acreages approved in SL -8, terminate monitoring surface and ground <br />water monitoring points and remove the greasewood reference area. <br />The Division has the following question about the submitted revised pages: <br />1. On pages 14-25 and 14-26, it states several times that the reclaimed ponds "will be evaluated against <br />the shadscale reference area if required." This is not a requirement according to the Rules. Rule <br />3.03.1(5) states that for temporary drainage and sediment control facilities, the "vegetative cover must <br />be adequate to control erosion and similar to the reclaimed area or surrounding undisturbed area." <br />Also, the former pond areas are located in valley bottoms while the shadscale reference area is on top of <br />a hill. This difference in topography will result in different plant communities and may create an <br />unachievable standard for the former pond areas. Does SCC want to have a commitment in the permit <br />that the ponds be evaluated against the shadscale reference area? <br />If you have any questions or need additional information, please contact me at (303) 866-3567 ext 8142. <br />Sincerely, <br />4a�L� <br />Brock Bowles <br />Environmental Protection Specialist <br />wov C%, <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining. state. co. us *` <br />John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director <br />