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and ditches were updated at that time as well to match the new drainage and pond <br />configuration. Other minor revisions have been made and include Minor Revisions MR -401 <br />through MR -403. Please refer to the updated maps and tables provided in these revisions. <br />9. Page 2.05-77, paragraph 3 states: <br />MCC plans to construct a monitoring well completed to the B -Seam, down -dip of <br />the Box Canyon longwall panels. The well will be drilled prior to longwall mining <br />panel 18 (the northern most Box Canyon panel). MCC will submit a revision to <br />show the location of the well and to include it in the monitoring program, prior to <br />beginning drilling. <br />Please update the text on page 2.05-77 <br />The referenced text on page 2.05-77 has been updated and is provided as part of the <br />attached Minor Revision MR -417. <br />Rule 2.05.6 - Mitigation of the Impacts of Mining Operations <br />10. Exhibit 38 gives Threatened and Endangered Species that have the potential to be <br />impacted by the West Elk mine, in accordance with Rules 2.04. 11(4) and 2.05. 6(2). <br />The Federal and State listed species of concern may have changed since the exhibit <br />was last updated. To find the most up to date lists, please reference the USFWS and <br />Colorado CPW websites. <br />Please update the species lists in Exhibit 38, and discuss potential impacts. <br />Threatened and endangered (T&E) species evaluations (or updates thereof) are conducted <br />as part of new construction revision applications as required. One example is the revised <br />RPEE designs that were submitted as part of Technical Revision TR -133. Table 9 of the <br />revised designs in Exhibit 82 provides listings of T&E plant and wildlife species along with an <br />evaluation of likelihood of onsite occurrence. MCC believes that Exhibit 38 is outdated and <br />unnecessary, so it is proposed to be eliminated as part of Minor Revision MR -417 and will be <br />replaced by case by case evaluations with revision applications, if needed. <br />Rule 2.10 — Maps and Plans <br />11. The area enclosed by the permit boundary is given on the RN -07 application <br />form as 17,154.9 Acres. In an attempt to verify this value, Map 01 was <br />georeferenced by PLSS section lines and the permit boundary digitized from that <br />image; the area calculated was 17,015 Acres. This example is typical of the <br />difficulties inherent in verifying boundary locations and the acreage of specific <br />areas from paper maps, particularly where those boundaries and areas do not <br />conform to physical features. <br />Currently the rules do not require that operators submit any geospatial data in a <br />digital format (although, text in the recent draft Stream Protection Rule put out for <br />public comment by the Office of Surface Mining Reclamation and Enforcement <br />suggests that this may be required in the future). This is the subject of frequent <br />discussion within the Division, and your input would be welcomed. <br />Would MCC consider submitting digital files to the Division in order to <br />accurately describe, for example, the permit boundary; the disturbance <br />boundary; bond release parcels; any other non-physical features required <br />to be displayed on maps? <br />MCC will consider working with the Division at a later date to provide digital files of <br />appropriate boundaries. <br />