2018-10-24_REVISION - C1981044

• Permit No: C1981044
• IBM Index Class Name: Revision
• Doc Date: 10/24/2018
• Doc Name: Adequacy Review Response #2
• From: Moffat County Mining, LLC
• To: DRMS
• Type & Sequence: RN7
• Email Name: RAR
• Media Type: D
• Archive: No

Rule 2.04.12 Prime Farmland Investigation
6. The Williams Fork permit states that the BLM made a negative determination far the presence ofprime farmland
based on soil type and precipitation. The BLM correspondence to support this statement was not found in the
permit Please provide this correspondence.
10 October DRMS
a. The paragraph referring to the amount of annual precipitation as a determinant of prime farmland is
not supported by Rule 2.04.12 -Prime Farmland Investigation. Please remove this paragraph as it
does not support the finding of `negative determination for the presence of prime farmland.'
b. A USDA, SCS letter dated December 23, 1986 was submitted with the last response from Peabody.
The letter states that the Eagle Mine has a growing season of 77 days. This information is
inconsistent with the permit Section 2.04.8 which states the mine area has a growing season of 120
days, and Exhibit K of the permit states the growing season is 94 days.
Please update these sections so the information is consistent.
Response: The reference to annual precipitation has been modified to clarify that, while not a determinant of
prime farmland, annual precipitation is a factor, along with growing season, relative to the potential for
agricultural uses. Contacts with CSU Extension have clarified average growing season, and the relevant permit
references have been updated for consistency. Copies of the updated permit materials accompany these responses
for replacement in the PAP.
Rule 2.05.6-11iti2ation of Impacts
11. Please update Map #25 to depict and or label the following structures and renewable resource lands: Oil pipeline,
County Road 107, Irrigation Ditches, Yampa River and Williams Fork River.
10 October DBMS
Adequately addressed with Map 25, with the exception of the irrigation ditches. DRMS was unable to locate
any irrigation ditches on the map nor is there a legend item referring to irrigation ditches. Please update the
map to indicate any existing irrigation ditches.
Response: Subsequent review of Map 25 has confirmed that the sole irrigation ditch on-site (Worthington Ditch)
is shown on the map.
Subsidence Survey
Page 2.05-52 indicates that three private residences are located within the permit area but are outside of the planned mining
area. Based on a review of Map 25 and Map 24, one private residence is located within the proposed longwall panel north
of the 101 East Gate Road.
12. Please update this section of the permit to indicate this.
a. In accordance with Rule 2.05.6(6)(b), please update this section of the permit to indicate the worst possible
consequences which subsidence, if it occurred, could have for this structure.
b. Also please update the subsidence control plan for the private residence to address the applicable
requirements of Rule 2.05.6(6)(n.
10 October DRMS
Adequately addressed with the exception that verbiage on revised pages 2.05-51 through 20.5-53 and 2.05-64
appear to require additional clarification of the fact that no future mining will take place at the site. For example
changing "will be undermined" "to would have been ", or "were not undermined because mining ceased in "...
As per pages 52 and 53 it is unclear to DRMS whether mining occurred in the Number 5 and Number 6 mines.
As per page 64, top of page contains an incomplete sentence: "The Oaki Plaza "...Please complete the thought