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Moffat County Mining, LLC <br />Ms. Tabetha Lynch <br />Colorado Division of Reclamation, Mining, and Safety <br />1313 Sherman Street — Room 215 <br />Denver, Colorado 80203 <br />(303) 866-3567 X8147 <br />29515 Routt County Road 27 <br />Oak Creek, CO 80467 <br />970-870-2718 <br />December 22, 2016 <br />Re: Moffat County Mining, LLC — William Fork Mines (Permit No. C-81-044); Technical <br />Revision No. 37 (TR37) Adequacy Response No. 1 <br />Dear Ms. Lynch, <br />Moffat County Mining, LLC (MCM) has reviewed your Adequacy Review No. 1 and has provided the <br />following responses to address the items of interest relative to TR37 submitted by MCM. <br />1. Regarding herbaceous production sampling, please revise proposed revised page 2.05-33, the first <br />sentence of the third paragraph to indicate that within each sample plot only the current annual growth <br />of herbaceous species will be clipped in accordance with Rule 4.15.11(1)(b)(i). <br />a. MCM RESPONSE: <br />Page 2.05-33 has been revised in accordance to Rule 4.15.11(1)(b)(i) and is included in <br />this Adequacy Response No. 1 and will need inserted in to the approved PAP after page <br />2.05-32. <br />2. The standard to be used to judge revegetation success for vegetation cover and productivity for the Utah <br />Tract is not clearly defined based on the proposed revision. The text would indicate success will be <br />based on a comparison of the reclaimed area to a reference area but then the text indicates the <br />revegetation success criteria for cover will be based on a prgposed technical standard. Also, a technical <br />standard for productivity is discussed. Overall, the text is confusing as to which standards will apply. <br />Based on a meeting with Jerry Nettleton that occurred last year, the Division assumes MCM would like <br />to use the technical standards. Please revise the text to clearly indicate what revegetation success criteria <br />will be used for cover and productivity for the Utah Tract. <br />a. MCM RESPONSE: <br />i. MCM would like to use Technical Standards developed within the Trapper Mine <br />Permit. MCM has revised page 2.05-35 to clarify the success criteria MCM would like <br />to use. This page has been included in this Adequacy Response No. land will need <br />inserted after page 2.05-34 in the approved PAP. <br />Page 1 of 2 <br />