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General comments: <br />As discussed in our January 21, 2005 meeting at the Paonia District Office, the FS would <br />strongly encourage Mountain Coal Company to establish a vegetative reference area on <br />the Forest. Due to the estimated number of methane drainage wells needed for the South <br />of the Divide area (76 wells and associated access roads) and their related surface <br />disturbances, it would appeaz to be beneficial, to MCC, CDMG, as wells as the FS, to <br />have a better representation ofpre-disturbance conditions. This "Forest reference azea" <br />would allow for more appropriate reclamation goals. That said, we offer our assistance in <br />selecting a suitable site as well as helping to complete the required transects. <br />• The GMUG would like a map included that shows the areas of potential rock fall and <br />predicted surface cracking (Dunrud's report). <br />The GMUG would also like a lazge format map that shows all of MCC's surface facilities <br />(including MDWs), mine plan, roads, azeas of rockfall, surface cracks, water resources, <br />surface ownership, lease boundaries, and topography. This map does not have to be <br />included into the permit, but would allow the FS to better evaluate potential impacts to <br />non-coal resources and provide more meaningful comments during the PR-10 review <br />process. <br />• The GMUG would like to meet with MCC and CDMG to formulate a collaborative <br />mitigation plan for repairing damage to springs, stock ponds, etc., should it occur, per the <br />requirements in the Federal Coal Lease stipulation that require repair of streams and <br />water resources. <br />• The GMUC would also like clarification on why the permit boundary is larger than the <br />lease boundary. As mentioned above, for portions of the permit azea MCC does not have <br />right of entry. These azeas have the potential, in future and current projects, to have <br />problems related to our environmental analyses. <br />The GMUG appreciates the opportunity to comment on this revision, and looks forward to <br />further discussions and information sharing. These comments do not offer the Forest Service's <br />formal concurrence to this mine plan revision. <br />Please contact Liane Mattson at (970) 874-6697 or Ryan Taylor at (970) 527-4131 should you <br />have any questions. <br />Sincerely, <br />/S/ LEVI K. BROYLES <br />LEVI K. BROYLES <br />District Ranger <br />Enclosures: Seed Mixtures for the Paonia Ranger District <br />