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r� TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 Sent via email: zach.truiillo(i,state.co.us DENVER, COLORADO 80233-0695 303-452-6111 July 16, 2018 Mr. Zach Trujillo Environmental Protection Specialist Colorado Division of Reclamation, Mining & Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 RE: Colowyo Coal Company L.P. Permit No. C-1981-019 Permit Renewal No, 07 Proposed Decision & Findings Document Comments Dear Mr. Trujillo, Tri-State Generation and Transmission Association Inc. (Tri-State), is the parent company to Axial Basin Coal Company, which is the general partner to Colowyo Coal Company L.P. (Colowyo). Therefore, Tri-State on behalf of Colowyo is submitting these comments on the findings document for Permit Renewal No. 7 (RN -07). The Division proposed a decision to approve RN -07 on July 9, 2018, and issued the proposed decision and Findings Document the same day. The public notice of the proposed decision published on July 13, 2018 in the Craig Daily Press and the Rio Blanco Herald Times, which initiated a 30 -day public comment period on the proposed decision. Tri-State has reviewed the proposed decision and Findings Document and provides the following comments on the Findings Document. 1. Section AT Prime Farmland & Alluvial Valley Floors, Page 29 — In the second paragraph the Division notes there are alluvial floors affiliated with Good Springs Creek, Wilson Creek, and Lower Elkhorn Creek. Under TR -109, data was submitted that demonstrated that alluvial valley floors are not present at Wilson Creek due to the mass wasting event that occurred in 1983-1984. Please see Volume 15 Section 2.06.8 and Map I IC. The Division approved this under determination under TR -109 on March 23, 2107. Based on this comment the Division needs to revise the findings document to remove Wilson Creek as being designated as an alluvial valley floor. 2. Section III. Hydrologic Balance — Rule 4.05, Part L, Alluvial Groundwater, Page 39. First, the Division needs to refer to comment 1 as it pertains to alluvial valley floors (AVF) for Wilson Creek. Second, also approved under TR -109, shown on Map 11C, and discussed in Volume 15 Section 2.06.8, Collom Gulch and Jubb Creek have also been determined to not be AVFs; therefore, the Division needs to update the entire Alluvial AN EQUAL OPPORTUNITY /AFFIRMATIYEACTION EMPLOYER A Touchstone Energy' Cooperative& CRAIG STATION ESCALANTE STATION NUCLA STATION P.O. BOX 1307 P.O. BOX 577 P.O. BOX 698 CRAIG, CO 81626.1307 PREWITT. NM 87045 NUCLA, CO 81424-0698 970-824-4411 505-876.2271 970.864-7316