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E~~i4 • s coa-cvrnpenr- Seneca Coal Company September 1, 2004 Daniel Mathews Division of Minerals and Geology RECEfv~p 101 South 3~d, Ste. 301 Grand Junction, CO 81501 S~P Q i (970) 242-5025 TQ~4 RE: Seneca II-W Mine (Permit No. C-1982-Q57) Division df Minerals and Geology PR-04 Response 2^d Adequacy Review Mr. Mathews: Enclosed please find two copies of revised and/or additional information for PR-04 addressing the remaining identified deficiencies in your July 7, 2004 letter. A third copy has been sent to the Division's Denver office also addressed to you. The responses to each of the adequacy comments are provided below and are numbered accordingly. 2.03.4 Identi~ration ollnterestr • 1. Updated ownership and control information war submitted in response to our original request to submit an updated Attachment 3-5, Owner, Offerer, and Director Information. However, bared on the current organizational structure of Peabody Energy Corporation as listed on the AVS ryrtem, further updates to Permit Tab 3 are warranted. Please update Tab 3 as appropriate ro reflect the current organization structure with the inclusion ofBTU Worldwide Inc., along with the necessary ownership and control information for BTU Worldwide Inc. Response: Information regarding BTU Worldwide Inc. has been attached 2. Original comment requested that Tab 3 Mapr (Exhibits 3-1, 3-2, 3-3, and 3-4) be cert~ed ar nguired by Rule 2.10.3(2). SCC provided jurtiftcation for not rert~ing the maps, and proposed that only 'designed or engineered" maps be certified for PR<7 and future revisions. We have considered this proposal and reviewed the matter with regard to program policy. We have concluded that the SCC proposal that only `designed and engineered" maps be certified doer not comply with Rule 2.10.3(2). The rule requires "tYlaps, plant, and trorr- sectionr....whirh are required by 2.10 shall be prepared by or under the direction of, and certified by, a qual~ed registered professional engineer or professional geologist, with auistance from experts in related freldr... " Artie 2.10.3(1) lists .rfiecfc features and attributer that are required to be depicted on permit application maps, and references in addition `any other maps specffirally required by Rule 2". Bole 2.103(1)(a) specifies that the permit application include maps showing all boundaries of lands and names of present owners of record of tbo.re lands, both surface and subsurface, included in or contiguous to the permit area ". As such, Exhibits 3-1, 3-2, 3- 3, and 34 do need to 6e certified. To the extent that the rer7~ing registered professional engineer or professional geologist tansiders subject maps or plans to encompass one or more disciplines beyond their competence, they may rely on consultanu or associates whom they know to Ge gualifred and rompetent in the applicable discipliner. Acknowledgement of the involvement of such gualifred and rompetent consultants and associates ran be included by • the registeredpmfessional engineer or professionalgealagisl in the cer7fration statemeret, without defeating the purpose of Rule 2.10.3 (2).