2017-11-20_REVISION - C1996084 - Laserfiche WebLink

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J, r- 1 � To: Rob Zuber From: Janet Binns Date: 11/20/2017 Re: Lorencito Canyon Mine RN4 PAR response review The Division sent a preliminary adequacy review letter to New Elk Coal Company (NECC) on August 7, 2017. The operator replied on October 16, 2017. 1 had identified two items that had conflicting statement in the Lorencito Permit text. These were identified as items #3 and #4. Item #3 identified conflicting statements regarding grazing management in the permit. I am questioning if NECC read the question. The Division asked NECC to correct conflicting statements in the permit regarding demonstration of achieving the approved post -mining land use and conducting vegetation sampling for bond release purposes. NECC's response was to state that they will not be grazing as per the post -mining land use of Rangeland, and did not provide corrected pages of the conflicting statements. The Division again respectfully requests that the conflicting statements on pages 2.05-60 and 2.05-72 be corrected. Page 2.05-60 references the last two (2) years, while page 2.05-72 commits to two (2) of the last five (5) years. Please just make these statement agree. Item #4 identified conflicting commitments on how woody plant densities will be measured. NECC's response was that they would deal with this issue at a later date. The Division simply requested that the stated methodology commit to either a 2 meter by 50 meter belt transect, or a 5 meter by 50 meter belt transect for woody plant density measurements. Currently it is unclear in the permit which method NECC will use. By choosing not to correct the error, potentially the Division could find the operator out of compliance with the permit if they choose to use a 5 meter wide or a 2 meter transect for woody plant sampling since the permit commits to both. Once again, the Division respectfully requests that NECC correct the conflicting text.