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GCC <br />GCC Energy, LLC <br />Telephone: 970.385.4528 6473 County Road 120 <br />0 Energy "Safety as a Value" Facsimile: 970.385.4638 Hesperus, CO 81326 <br />July 27, 2016 <br />State of Colorado <br />Division of Reclamation, Mining & Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Attn: Rob Zuber, Environmental Protection Specialist II <br />Re: GCC Energy, LLC <br />King I & II Mines <br />CDRMS Permit # C-81-035 <br />Technical Revision #24 - Midterm Permit Review No. 7 (MT -07) <br />CDRMS Permit Information Database Reconciliation <br />Dear Mr. Zuber: <br />As you are aware, during review of Technical Revision #24 (TR -24), several discrepancies have been <br />noted concerning the various acreages (Disturbed, Affected, Permit, State, Federal and Private, etc.) <br />as listed in the Colorado Division of Reclamation, Mining & Safety (CDRMS) permit information <br />database. After considerable research by CDRMS and GCC Energy, we feel that most of these <br />discrepancies were due to three main causes: <br />As various permit revisions have been approved, the acreages involved have been incorrectly <br />entered into the CDRMS database. <br />2. Most of the parcels listed in the Permit documents are entered as detailed on the associated <br />coal leases. These leases are generally listed as aliquot parts of Sections, Townships and <br />Ranges and not in actual surveyed acreages. For example, Section 36, Township 35 North, <br />Range 12 West, NMPM is listed on the coal lease and entered into the CDRMS database as <br />640 acres. The actual surveyed acreage of this Section is 694.2 acres. <br />3. At least 2 comprehensive dependent re -surveys by of the area by the Bureau of Land <br />Management since the Permit was first issued in 1982, as well as several professional <br />surveys contracted by GCC Energy and its predecessors, have proven the acreages to be <br />somewhat different that that listed in the permit documents and the CDRMS database. <br />Permit Area <br />In order to correct the database and provide an accurate representation of actual "On the Ground" <br />boundaries of the Permit Area, Affected Area, Disturbed Area, etc., GCC Energy has, in cooperation <br />with CDRMS, prepared the following table and maps to describe, to the best of our knowledge, <br />acreages which should be listed in the CDRMS database. Table 1: Permit Boundary Revisions <br />shows a comparison between acreages as approved in the CDRMS database with actual acreages as <br />surveyed. An 80 acre area of Section 36, T35N R12W (PR -04(b)) is shown in the table as removed <br />from the total as it was counted twice with the approval of PR -08. The "Kambe Lease" (PR -02(b)) is <br />also shown as being removed from the total since it was removed from the Permit Boundary area as <br />part of Permit Renewal RN -06 on 3/7/13. <br />