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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 28, 2016 <br />Re: Lorencito Canyon Mine (Permit No. C-1996-084) <br />Minor Revision 14 (MR -14) second adequacy letter <br />Dear Mr. Head: <br />I have reviewed the MR -14 submittal and the NECC adequacy responses (letter dated March 24, <br />2016 and associated documents), and I have the following comments. The numbers correspond <br />to numbers in my first adequacy letter of March 8, 2016. <br />1. No additional response required. <br />2. It appears there is a mistake with the cover management (C) values in the RUSLE <br />demonstration. The values of 0.06 used for all pre -mining conditions should possibly be <br />0.006 (an order of magnitude smaller) per Table 10 in Exhibit 15 of the Lorencito Canyon <br />PAP. Please determine if this is accurate and further explain the origin of the value of 0.06. <br />3. It is still unclear how length factors were measured, since no maps were provided. However, <br />it appears that for several of the reclaimed areas the lowest portion of the fill (directly above <br />the pond) was used, and for the pre -mining condition the upper portion of the drainage area <br />was used since the lower portion of the area is channelized. Please confirm if this <br />assumption is correct or incorrect. If it is incorrect, please elaborate on the determination of <br />the length factors. <br />Please feel free to contact me with any questions or comments. <br />Regards, <br />Robert D. Zuber, P.E. <br />Environmental Protection Specialist 11 <br />of .0 <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 />