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TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. <br />HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 <br />September 14, 2018 <br />Mr. Zach Trujillo <br />Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining & Safety <br />Department of Natural Resources 0 <br />1313 Sherman Street, Room 215 �yE <br />Denver, CO 80203 <br />P��2p16 <br />RE: Colowyo Coal Company L.P. <br />Permit No. C-1981-019 <br />Technical Revision No. 123�pa�y <br />Adequacy Response <br />Dear Mr. Trujillo, <br />Tri-State Generation and Transmission Association Inc. (Tri-State), is the parent <br />company to Axial Basin Coal Company, which is the general partner to Colowyo Coal Company <br />L.P. (Colowyo). Tri-State received your adequacy letter dated September 9, 2018 and is <br />providing the response below to your adequacy concern on behalf of Colowyo. The Colowyo <br />Mine operates under Permit No. C-1981-019. <br />1. Colowyo's comparison of Danforth Hills Aspen Study Area cover data and Collom Aspen <br />Reference Area cover data was acceptable, but the "Reference Area Statistical <br />Comparison Table" needs to reflect that 15 transects were collected in 1984 not 13. <br />Likewise on this table, the comparison of Danforth Hills Aspen Study Area production <br />data and Collom Aspen Reference Area production data was acceptable, but the table <br />needs to reflect that 13 transects were collected in 1984 not 15. Please update the <br />"Reference Area Statistical Comparison Table" with the correct number of transects. <br />Response: The error in the number of transects for the Danforth Hills baseline has been <br />corrected to "15" as noted. <br />2. On the Exhibit 10 -Item 6, "Reference Area Statistical Comparison table ", Colowyo used <br />a vegetative cover value of 74.3%for the 1984 Danforth Hills Aspen Reference Area <br />value in its comparison with the 2005 Collom Aspen Reference Area. The Division was <br />unable to locate where Colowyo found the 74.3% cover value. All of the 1984 Danforth <br />Hills data show that the Aspen Reference Area cover was 78.1 %. CCC also submitted a <br />new Table 5 that reiterates the "Danforth Project Vegetation Cover -1984 Aspen <br />Reference Area" with yet a different value for the 1984 Aspen Reference Area vegetative <br />cover of 94.27%. Exhibit 10 Item 5, Tables 3.3, 3.6, and the tabulated data sheet for the <br />1984 Aspen Reference Area all report 78.1 % vegetative cover. Please correct the value <br />for the 1984 Aspen Reference Area cover, re -runt the comparison, and resubmit the table. <br />AN EQUAL OPPORTUNITY 1 AFFIRMATIVE ACTION EMPLOYER CRAIG STATION eSCALANTE STATION NULLA STATION <br />P.O. SOX 1107 P.O. SOX 577 P.O. SOX 690 <br />A Touchstone EneWCooperadve ,)Ic aUUG, CO 0162&1107 NW&M. NM 87M NUGA, CO 81424-O0 <br />�..,� 9M-824-4411 50541Ii7271 970-6/-"16 <br />