Laserfiche WebLink
E <br />S co,u company <br />Seneca Coal Com <br />September 14, 2005 <br />Mr. Daniel Mathews <br />Division of Minerals and Geology <br />101 South 3b, Suite 301 <br />Grand Junction, CO 81501 <br />(970) 242-5025 <br />RECEIVED <br />SEP 19 2005 <br />p~WOn of Minerals and Gedc6Y <br />RE: Seneca II-W Mine (Permit C-1982-057) <br />Permit Revision No. 5 (PR-5) <br />Worst Case Reclamation Cost Esrimate <br />Mr. Mathews,-- - - - - - --- _ _ - -- -- -- - - -- -` -- ~-- <br />Seneca Coal Company (SCC) has reviewed your letter of September 6, 2005 regarding the RN-4/PR-5 cost estimate <br />calculation that represents an increase of $496,290. SCC has a number of issues with this increase and is providing this <br />letter as appropriate documentation to justify a lower amount. <br />First and foremost, at our meeting with the Division, on July 19~ in Denver, it was our understanding that the bond <br />amount would not increase beyond the amount currently held by the Division. In addition, the following items aze <br />provided for clarification and justification for remaining at the current bond levels. <br />• It appears that the Division misunderstands SCC's request regarding the bonding situation. SCC is not <br />requesting a bond reduction from the current held amount of $9,707,373, but is requesting that the Division <br />not increase the bond amount. <br />• As the Division stated the `4vorst case" condition calculated was in August 2004. The time to increase the <br />bond amount to meet the August 2004 state of disturbance was prior to August 2004 not a year later when the <br />condition no longer exists. As the Division is aware, considerable backfilling and grading has taken place in <br />2004/2005 (contemporaneous and variance catch-up), which has significantly reduced the xedamation liability. <br />It seems to SCC that if the Division is required to recalculate the bond, then the airrent or future worst case <br />condition should be used, not a situation ox condition that no longer exists. <br />Based on the Division's deusion regarding the Yoast Mine RN-02 whereby the bond amount was not increased but <br />instead held at the current amount so that there is no "de facto" bond release, SCC requests that the same decision be <br />reached concerning the II-W Mine. <br />Sincerely, <br />~_ <br />Roy A. Kazo <br />cc: Sandy Brown (DMG) <br />Jim Stark (DMG) <br />Brian Dunfee (Peabody Energy) <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 278-3707 • FAX (970) 276-3074 <br />