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TWENTYMILE COAL, LLC - FOIDEL CREEK MINE (C-82-056) <br />PR14-10, WOLF CREEK RESERVE DEVELOPMENT AND MINING <br />TECHNICAL ADEQUACY 5 RESPONSES (03/16) <br />Rule 2.03.6 — Right of Entry Information <br />4) Page 2.05-3 indicates that Twentymile Coal, LLC (TC) is pursuing leasing the Federal coal with a <br />Lease By Modification (LBM) for the inclusion of the Wolf Creek Seam in the Federal Coal Lease COC -54608. <br />The Division cannot approve a mine plan that includes mining in the Wolf Creek Seam within this area until the <br />LBM has been approved. Should the LBM not be approved by the time all other PR -10 adequacy issues have <br />been resolved, TCC will have to request continued extension of the decision due date until the LBM is approved. <br />TC's response: TC recognized and discussed this constraint with the CDRMS at the time the PR10 <br />application was submitted. TC will monitor the status of the pending federal lease modification and <br />coordinate with the CDRMS relative to extension of the decision date for the PR, and submittal of the lease <br />documentation when it becomes available. <br />Division's response: This item remains outstanding and will need to be addressed prior to the approval of <br />PRIO. <br />TC's response: The BLM has issued the Lease Modification, a copy of which accompanies these responses <br />for the file. TC has reviewed and revised the PAP text, as appropriate, and copies of the revised text page(s) <br />accompany these responses for replacement in the PAP <br />Rule 2.05.2; Operation Plan — Estimate Area for Life of Operations <br />10) Revised Page 2.05-3 and 2.01-4 indicates the permit area is 22,447 acres and 22,607 acres <br />respectively. Revised page 2.01-4 appears to include the 160 additional permit acreage proposed with PR10. <br />The Division's records indicate the current permit acreage for the site is 20,100 acres and with the approval of <br />PR10, the permit acreage will be 20,260 acres. Based on the Division's files, it appears TC reduced the permit <br />area with TR51 to 22,443 acres. TC requested to increase the permit area by 80 acres with TR81 for a total <br />permit area of 22,530 acres. Subsequently, with Permit Renewal No. 6 (RN6), the permit area was cited to be <br />22,450 acres. In the most recent technical revision, TR83, the permit area was cited to be 22,450 acres. Please <br />review the permit acreage and permitting history and verify that the permit acreage will be 22,607 acres with <br />the approval of PRIG. <br />TC's response: The Permit Area acreage figure has been checked and updated for consistency. Revised <br />copies of the referenced page accompany these responses for replacement in the PAP. <br />Division's response: We spoke on the telephone on July 14, 2015 regarding how TC verified the 22,607 <br />acres. Based on this conversation, TC's draftsman calculated this area based on the permit boundary <br />depicted on the mining plan map #23. The original adequacy question indicated that TC requested to <br />change the permit area by 80 acres with TR81, this was incorrect. It appears TC requested to increase the <br />permit area by 80 acres with TR82. Based on the Division's decision form for TR82, the Division approved <br />an increase of 160 acres. It is unclear why there is a discrepancy in how many acres TC requested to <br />increase their permit area by and how many acres the Division ended up approving. Given this, I compared <br />the permit boundaries depicted on Map 23 approved with TR82 and the map that was previously approved <br />prior to TR82 which appears to have been revised with TR78. It appears the permit boundary was modified <br />in two areas based on these maps. One area is located in the NE'/ of Section 34 of TSN, R87W. The second <br />parcel is located in the NE '/ of Section 13 of TSN, R87W. A map depicting these two areas is enclosed to <br />assist with this review. Does the 22,607 acre total permit area projected with PRIO include these parcels? <br />