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<br />Response - Only a portion of the Lorencito Canyon haul road will be used for the contour <br />mining operation. The existing road has been upgraded for coalbed methane development and <br />this road will be used for coal haulage. Those areas of additional disturbance have been <br />surveyed and the results submitted in the PR-I cultural resource reports. <br />Rule 2.04.6(2) Geoloav Description <br />Please submit laboratory results for the recent drilling activities conducted in March 2001 for <br />the proposed contour mining azeas required by Rule 2.04.6(2)(6). <br />~i~e~ Response -Attached for inclusion into Exhibit 6 of the Permit is a copy of all laboratory <br />`~ .t~ analyses obtained from the March 2001 drilling program. <br />Rule 2.05.3(2) Operation Plan Description <br />6a. Permit text and maps, as proposed, results in a somewhat confusing understanding of exactly <br />what activities are being requested for approval. Map 2.05.3-1, Mine Plan, seems to present a 5- <br />year mine plan that will start upon final approval of PR-Ol. Color codes are used to depict the <br />surface mine sequence. These color codes, although underground mines aze presented in color, <br />do not seem to apply to the proposed underground mining, given the estimated years annotated. <br />If underground mining is to occur, why are reclamation costs not included for underground <br />mining? Facility information is included for underground operations, yet bond calculations <br />• include no cost estimates for reclamation of these areas. <br />Revised permit text reads "Only surface mining...during the first permit term". Other permit <br />text on page 2.05-3, 3rd pazagraph reads "...5 year permit term". The current permit expires in <br />November 2002. We are currently in the fourth year of the first permit term. <br />Disturbance area timetable on page 2.05-3a indicates 350 acres will be disturbed in the year <br />one of mining. An additional 290 acres will be disturbed in year two. Review of the bond <br />calculations submitted (revised page 3-12) indicates 22.4 acres is presented as the worst case <br />disturbance for the Jeff Canyon mine. <br />No change is proposed in the haul road disturbance acreage shown in table 2.05.4-1. This <br />would seem to indicate no change in the approved plan regarding haul roads. Page 2.05-336 <br />refers to roads and railroads. The DMG understands that no rail spur is proposed. On Table <br />2.05.3-2 (page 2.05-34), regarding topsoil stripping, the acreage for roads, portals, and loadout <br />did not change, even though the disturbed area was expanded and the physical location of the <br />loadout changed. <br />The Division requires that a permit application clearly indicate the approved mining and <br />reclamation plan. Once that plan is determined, a cost estimate is developed and a performance <br />bond, in the amount necessary to complete the approved plan, is submitted and approved. It is <br />not clear at the present time whether LLC is asking fora 5-year mining plan, an eleven year <br />. mining plan (see disturbance area timetable), a l7-year mine plan (see map 2.05.3-i, year 2018), <br />