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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />I upattment Gt Naiwat Rcsow CP> <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />March 9, 2016 <br />Jerry Nettleton <br />Twentymile Coal, LLC. <br />29515 Routt County Road 27 <br />Oak Creek Colorado, 80467 <br />RE: Foidel Creek Mine; C-1982-056 <br />9 East Utility Borehole, MR296 Application, Adequacy Review No. 1 <br />Dear Mr. Nettleton, <br />The Colorado Division of Reclamation, Mining and Safety received the above referenced application on <br />April 22, 2016. The application was deemed complete on May 9, 2016. After review of the application <br />for technical adequacy, there are several items that will need to be addressed prior to the Division's <br />approval of the application. Each items is listed below under the Rule and permit section to which they <br />pertain. <br />2.04.4 — Cultural and Historical Resources, 2.05.6(4) Protection of Historic Resources: <br />1. Proposed revised page 2.04-9.2, does not follow with the preceding page. It appears this page is <br />missing formation that was added with PRI 1. Please revise the page as necessary and review this <br />page and insure it follows with the preceding and following page. <br />2. Included with the submittal was a Class III Cultural Resource Inventory report prepared by <br />Metcalf Archaeological Consultants dated August 2015. This report, herein called the Metcalf <br />Report, is to be added to Exhibit 6T based on the summary of revisions and additions sheet <br />submitted with MR296. The Metcalf Report is a duplicate of the report that is already included in <br />Exhibit 6L that was added to the permit with the approval of MR289. Given this, it does not <br />appear it is necessary to add this report to Exhibit 6T. Please revise page 2.05-45.30 to cite that <br />the Metcalf Report is included in Exhibit 6L and dated August 2015 to differentiate it from other <br />surveys currently included in Exhibit 6L. Also please provide an updated coversheet for Exhibit <br />6L to indicate that it includes the MR296 survey area. <br />3. According to the Metcalf Report, Site 5RT3325 and 5RT3324 are eligible to be listed on the <br />National Register of Historic Places (NRNP). Site 5RT3325 is located within the disturbed area <br />if the Option #3 drill pad is constructed. Given this, the statement made on proposed revised <br />page 2.04-9.2 that the proposed project will not impact identified cultural resources is not <br />accurate and will need to be revised. TC will need to revise their plan or remove Option #3 in <br />order to avoid disturbing this site. Avoidance of the site or further testing/mitigation of the site is <br />recommended by Metcalf Archaeological Consultants on page 21 of the Metcalf Report. <br />-0V ci?zo � <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 />