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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Louis Head <br />New Elk Coal Company, LLC <br />12250 Hwy 12 <br />Weston, CO 81019 <br />March 8, 2016 <br />Re: Lorencito Canyon Mine (Permit No. C-1996-084) <br />Minor Revision 14 (MR -14) adequacy letter <br />Dear Mr. Head: <br />I have reviewed the MR -14 submittal, and I have the following comments. <br />L In Exhibit 15 - Subpart H of the submittal there are tables of inputs for the universal soil loss <br />equation (one table for each outfall). The C factor in these tables is called "cropping <br />management factor" rather than "cover management factor." Most textbooks describing the <br />methodology for the RUSLE use the term "cover management factor." Please explain. <br />2. Please elaborate on how the existing Exhibit 15 was used to develop the C values in the <br />universal soil loss equation analyses. Where does the value of 0.003 originate? Was <br />vegetation sampling data used to develop this value? If not, please explain why. <br />3. Please elaborate on how the LS values were determined. The best way to do this is to provide <br />topographical maps showing the locations of where lengths and slopes were calculated. If <br />maps are provided, some examples would suffice; a map for every analysis is not necessary. <br />Please feel free to contact me with any questions or comments. <br />Regards, <br />Robert D. Zuber, P.E. <br />Environmental Protection Specialist II <br />QF GQ�Q <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 * * 1g76 <br />