Laserfiche WebLink
COLORADO <br />Division of Reclamation, <br />j&7 Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />July 6, 2018 <br />Mr. Jeremy Nichols <br />Ms. Shannon Hughes <br />WildEarth Guardians <br />2590 Walnut Street <br />Denver, CO 80205 <br />RE: West Elk Mine, C-1980-007, PR -15 <br />Response to Follow-up on Informal Conference Request and Site Visit on June 21 <br />and 22 <br />Dear Mr. Nichols and Ms. Hughes: <br />The Division appreciates your time to engage in the informal conference process with the on the <br />ground site visit of the proposed permit area on June 21 st and 22nd. As you know, the Division <br />determined the PR -15 application complete for the purposes of filing on April 5, 2018. As a part <br />of the Division's completeness review, it was determined that the application submitted <br />minimally addressed all requirements associated with the activities proposed. The terms <br />"completeness" and "adequacy" have specific meaning within the Division's internal application <br />review process. It is not unusual, as is the case here, for an application to be found "complete" <br />for the purposes of filing, but not yet adequate. Please understand that a determination of <br />completeness does not mean the application has adequately addressed all associated <br />requirements. <br />A finding of completeness is a threshold administrative determination, allowing the Division to <br />commence a more thorough technical review (referred to internally as an adequacy review). For <br />example, your June 25, 2018 letter stated that "Mountain Coal has not provided "detailed" <br />information regarding the location of roads and methane drainage wells." However, Mountain <br />Coal Company did provide information regarding the locations of roads and support facilities <br />with the PR -15 submittal. By providing this information, the portion of the application regarding <br />the locations of roads and support facilities was "complete". <br />In addition, your letter cites the Division's adequacy review of the proposed mine plan. The <br />submittal of a mine plan, even if not -yet adequate, is sufficient to allow the Division to determine <br />an application is complete, allowing the Division to commence the adequacy review process <br />related to the mine -plan. As noted in the Division's adequacy letter, the proposed mine plan is <br />inadequate and more information is required, however, this does not mean that the application <br />was incomplete. It is the Division's thorough adequacy review of the information that <br />flF'C-0 <br />H <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us I <br />John W. Hickenlooper, Governor I Robert W. Randall, Executive Director I Virginia Brannon, Director * r 1876 4 <br />