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indicated, on our June 21 and 22 site visit, we were denied access to nearby private lands for <br />purposes of ascertaining the condition of a potential access road. At that time, Mountain Coal <br />indicated the reason for the access denial was that the company lacked any right of entry to <br />access private lands that would be utilized to access the PR -15 area; rights which were required <br />to be provided for in Mountain Coal's initial application. Additionally, DRMS staff indicated <br />that the PR -15 application submitted by Mountain Coal was so preliminary that it would <br />preclude any meaningful assessment of whether access via private lands would be more ideal at <br />that point in time. This included that the location of well pads and roads were bound to change <br />and have indeed since changed the initial application was submitted to DRMS in the spring. This <br />raised serious concerns that DRMS's April 5, 2018 completeness finding for Mountain Coal's <br />PR -15 application was premature. It is difficult to see how a legitimate completeness <br />determination could be issued, where, as here, the information was not "accurate and complete" <br />as 1.4.1(3) requires. <br />While Mountain Coal provided maps to Conservation Groups for the site visit, Mountain <br />Coal changed these maps significantly several times between the site visit and the August 1, <br />2018 informal hearing. Compare PR -15 -Map 51 "E -Seam Projected Operations" (March 19, <br />2018), attached as Exhibit 5 with PR -15 -Map 51-Rev2 "E -Seam Projected Operations" (June 29, <br />2018), attached as Exhibit 6. It appears Mountain Coal submitted its application before it had <br />completed its exploration for the area, and dramatically modified its proposal only after some of <br />the exploration was complete; modifications are detailed below, with maps. <br />In comparison, Mountain Coal's March 23, 2018 application proposed to add two <br />recently approved federal coal lease modification to the mine's permit area. The Lease <br />Modifications area consists of 1,520 acres that are part of the Grand Mesa, Uncompahgre and <br />Gunnison National Forest, including lands that are part of the Sunset Roadless Area. The permit <br />revision would also add additional adjacent private land, sanctioning access to an additional <br />1,100 acres of both private and publicly -owned coal. The permit revision relied on the prior <br />SFEIS, which assumed that "72 total acres of vegetation disturbance would occur from mine <br />operations over the life of the lease modifications [... ] Site-specific locations of anticipated <br />disturbance cannot be identified at the leasing stage as a final mine plan has not been approved" <br />incomplete. The application does not (and apparently cannot yet) provide detailed information regarding the location <br />of roads and support facilities that would be constructed, maintained, and utilized as part of the PR -15 revision.") <br />