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E S coacornp.nr Seneca Coai Company April 3, 2006 Mr. Mike Boulay Division of Minerals and Geology 1313 Sherman Street, Room 215 A~l~ Q Q 2~~6 Denver, CO 80203-2273 Division of y~merals and Geology RE: Seneca II Mine Permit G80-005 Technical Revision No. 40-Vegetation Evaluation Procedures for Phase III Bond Release 1•~ Response to Adequacy Comments Dear Mr. Boulay, Enclosed please find three (3) copies of revised and supplemental information Eor TR-40, corresponding to the Division's adequary review letter of January 10, 2006. The responses to the adequacy comments aze provided below and are numbered accordingly. 1. The dircursiou under INTTtODUCI70N, on page 1 of the appendix acenrately rummari~er the revegetation success demonstration requirements in effecS for lands reclaimed during specified times, within the Senear II Mine permit barmdary. The final sentenn on page 1 states that the `youn8erllandr, which fall under thin (permaneniprogramJgeneral requirement (as of September 2005), were fart needed in 1995': This statement could be somewhat misleading, because the lands included in Bond Release Block 4, which were reclaimed between 1996 and 2003, and lands in Bond Release Block S, which have notyet been reclaimed, would oleo fall under the permanent programgenerol requirzmenu. The intent of the section might be clarified by replacing the final sentence with a new paragraph, similar to the following: It it anticipated that final bond ukase for lands within the Seneca 77 permit aria will be requested under two or more applications to be submitted overaperiod of 10 ormoreyearr. The imitral app/iration forPhare III bond release is schedrtled for submittal in 2006 or 2002 The initial application will include lands reclaimed prior to issuance of the permanentprogram reguirements (September23, 1981), as well as /ands reclaimed on or after [hat dale. The most recently reclaimed lands to be incGrded in the initial Phase III bond release application wen last needed in 1995. Please include the above paragraph or similar clarifying latrguage in the Introduction section of the appendix. Response: The language has been included. 2. Bond Release Blocks are described on page 2 and delineated on Exhibit 13.13.1. In the first sentence under the Bond Release Block (BRB) section heading on page 2, then it reference to three BRB% However, five BRB'r an lured in the section and delineated on Exhibit 13-13.1. For rnnsistency and clarity, we request that the &rst sentence be amended to refer ro ``five"bond release blocks rather than "three"bond r;e%ase blocks. Further, we suggest that an additional sentence be added to the first paragraph on page Z, explaining drat BIZB's 1, Z, and 3 will be included m the initial bond release application to be submitted in 2006/2007, while BRB's 4 and 5 will be included m subsequent bond release applications Finally, me request that the brief Seneca Coal Company . P.O. Box 670 . Hayden, Colorado 81639 Telephone (970) 276-3707 • FAX (970) 276-3014