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Mountain Coal Company <br />May 20, 2016 <br />Mr. Leigh D. Simmons <br />Mountain Coal Company, LLC <br />West Elk Mine <br />P.O. Box 591 <br />Somerset, CO 81434 <br />Kathleen G. Welt <br />Environmental Engineer III <br />kweltca archcoal.com <br />phone: 970 929 2238 <br />RECEIVED <br />Colorado Division of Reclamation, Mining and Safety MAY 2 4 2016 <br />Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 DMSION OF RECLAMATION <br />Denver, Colorado 80203 MINING AND WETY <br />Re: Mountain Coal Company, LLC, West Elk Mine; Permit No. C-1980-007; <br />Permit Renewal Application No. RN -07, Responses to Initial Adequacy Review <br />Dear Mr. Simmons: <br />Mountain Coal Company, LLC (MCC) submits the following responses to the Division's initial <br />adequacy review. The adequacy comments are provided below in italics and are followed by <br />MCC's responses. <br />Rule 2.03.4 — Identification of Interests <br />1. Exhibit 1 gives information concerning officers and directors. <br />Please ensure that Exhibit 1 is updated as officers and directors change <br />throughout the process of approval for RN -07. <br />MCC updated all Officers & Directors lists earlier this year with MR -416, and no further <br />changes are expected this year. If an unexpected change does occur, a revised list will be <br />submitted in a revision application. <br />2. Exhibit 2 gives the status of permits and approvals for Mountain Coal Company, LLC <br />and other mines owned by Arch Western Resources, LLC. <br />Please verify that the information in Exhibit 2 is complete and accurate; note that <br />rule 2.03.4(4) refers to "...any surface coal mining operation owned or controlled <br />by either the applicant or by any person who owns or controls the applicant..." <br />which the Division interprets in this case as any surface coal mining operation <br />within the Arch Coal, Inc. corporate hierarchy. <br />MCC is 100% owned and operated by Arch Western Bituminous Group, LLC (AWBG) as is <br />stated on page 2.03-4 of the current permit document that was updated earlier this year in <br />revision MR -415. Exhibit 2 has been updated with current information for the three AWBG <br />operations and is provided in the attached application for Minor Revision MR -417. <br />3. Exhibit 3 gives a complete list of the owners of record. <br />Please verify that the records of all surface and mineral owners of property <br />contiguous to the permit area are complete and accurate in Exhibit 3, and that the <br />information is consistent with Maps 2 and 4. <br />MCC updated Exhibit 3 and Map 2 with MR -384 in December 2011. Map 4 was updated <br />with PR -12 in 2008. To the best of our knowledge and belief, no changes have occurred in <br />surface or mineral ownerships since these revisions were approved. <br />Rule 2.05.2 — Operation Plan — Estimated Area for Life of Operation, <br />