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New Elk Mine, PR5 Adequacy Review 1 <br />September 2, 2021 <br />Page 3 of 6 <br />Rule 2.04.4 — Cultural and Historic Resource Information <br />15. On August 6t1i, 2021, DRMS received the enclosed undated letter from History Colorado, from the State <br />Historic Preservation Officer (SHPO). They requested additional information from DRMS regarding PR5 <br />which we have provided to them. Also, the SHPO recommended that a class III cultural resource inventory be <br />completed prior to construction activities to determine the presence of cultural resources in the area of potential <br />effect and to assess the eligibility of any resources for the National Register of Historic Places (NRHP). Rule <br />2.04.4 requires such an analysis for areas potentially impacted by surface activities or probable subsidence. <br />Given this, DRMS sought clarification on SHPO's recommendation since no new surface disturbance is <br />proposed with PR5 and since subsidence is not anticipated given the proposed mining method. SHPO <br />responded to DRMS with the enclosed correspondence dated August 20, 2021. Upon review of Section 2.05.6 <br />of the PAP and Exhibit 24, the current mine plan and subsidence control plan anticipates multi -seam mining <br />and planned subsidence from retreat mining in certain circumstances. Please see the adequacy review questions <br />under the section for Rule 2.05.6 below. Either provide the results of the class III cultural resource survey and <br />update Section 2.04.4 accordingly, or provide a detailed rationale for not providing this information. <br />Rule 2.04.5 — General Description of HydroloEy and Geolo�v <br />16. Please revise Map 5 and 6 to depict the revised permit boundary. <br />17. Map 7 includes geologic cross sections, however the A -A' cross section does not extend into the proposed PR5 <br />expansion area fully to the northeast. Please update Map 7 to take the expanded permit area and affected area <br />into account. <br />18. Current page 2.04-11e states core holes were drilled in 2020 and 2010 however it does not indicate where in <br />the permit the drill logs for these holes are located. Please revise this section of the permit to indicate where <br />these drill logs can be found in the permit and please provide this information as an exhibit to the permit in <br />accordance with Rule 2.04.6(3)(a)(111)(A). <br />19. PR5 proposes room and pillar mining in the Blue Seam. Please revise permit section 2.04.6(3)(a)(iii)(E) with <br />the thickness and engineering properties of clays or clay shale, if any in the stratum immediately above and <br />below the coal seam to be mined. <br />Rule 2.04.7 — Hydrology Description <br />20. The legend of Map 8 does not appear to be reflective of the various lines and symbols used on the map. For <br />example the revised PR5 permit boundary appears to be a thick green line not an orange -yellow dashed line as <br />the legend indicates. Also there is a red dashed line that appears to delineate the pre-PR5 boundary. Please <br />revise the map so it features are accurately portrayed in the legend. <br />21. Please update Section 2.04.7, Map 8, and Map 20 to depict and provide updated information required by Rule <br />2.04.7(1)(a)(iv) and (4)(a). <br />22. Currently page 2.04-19 indicates dewatering of the Allen and Apache coal seams for mining is not expected to <br />lower water levels in alluvial wells but may impact bedrock wells. Is dewatering necessary for mining in the <br />Blue Seam? If so, what impact will it have on alluvial wells? What impact will it have on the bedrock wells? <br />Please revise page 2.04-19 to include this information. <br />