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TWENTYMILE COAL, LLC, FOIDEL CREEK MINE (C-1982-056) <br />PR18-12 WOLF CREEK RESERVE LBA DEVELOPMENT AND MINING <br />TECHNICAL ADEQUACY RESPONSES 01/19 <br />The Division received a comment letter on December 17, 2018 from the Office of Archaeology and <br />Historic Preservation. The letter notes that while there are no surface facilities planned at present, there <br />may be potential subsidence impacts. <br />The letter states that a search of the Colorado Cultural Resource Inventory Database indicates that 7 <br />cultural resource inventories have been conducted in the vicinity of the proposed area to be added to the <br />existing permit, and cultural resources which may be eligible for listing to the National Register of Historic <br />Places have been recorded therein. Files contain incomplete information for this area and for this area and <br />there is the possibility that as yet unidentified cultural resources exist within the proposed permit area. <br />1. Please address the issues from the above stated comment letter with documentation to be placed in the <br />PAP. <br />Response: TC has checked survey coverage for this area with our archaeological consultant and has <br />scheduled with them to complete supplemental survey work this spring, as soon as ground conditions <br />allow. They will coordinate with the Cultural Resource Specialist for the BLM's Little Snake Field Office <br />to assure that any applicable federal consultation requirements are addressed appropriately. The relevant <br />PAP text will be reviewed and modified, if appropriate, to reflect the supplemental survey, and the survey <br />report will be submitted for inclusion in Exhibit 6L of the Confidential Appendix. <br />2. Please provide any updates to the mine's Identification of Interests in Sections 2.03.4 <br />Response: Section 2.03.4 and the associated maps have been reviewed and updated if appropriate to <br />reflect any recent changes. Copies of updated documentation accompany these responses for replacement <br />in the PAP. <br />3. In accordance with Rule 4.20.2, Twentymile Coal, LLC (TC) will need to distribute by mail the mining <br />schedule to all owners of property and residents within the area above the underground workings and <br />adjacent areas. Notification is required at least six months prior to mining beneath the property or <br />residence. <br />a. Please inform the Division if these notifications been sent and if documentation is available for <br />review. <br />b. Please ensure the surface/subsurface ownership information and maps have been reviewed and <br />updated. <br />Response: The surface and mineral ownership information and maps have been reviewed and updated if <br />appropriate (see previous response to Comment 2). The landowner notification required under the <br />referenced Performance Standard has been submitted to all potentially affected owners/residents. A copy <br />of the notification and mailing list accompanies these responses for reference. <br />4. The Division understands that TC is pursuing leasing the Federal coal with a Lease by Application <br />(LBA) for the Wolf Creek Coal Seam under Federal Coal Lease COC- 78449. Per Rule 2.03.6 Right <br />of Entry, the Division cannot approve a mine plan that includes mining in the Wolf Creek Seam within <br />this area until the LBA has been approved. Should the LBA not be approved by the time all other PR- <br />