PERMFILE128862

• Permit No: C1980007
• IBM Index Class Name: Revision
• Doc Date: 6/13/2005
• Doc Name: 2nd Adequacy Response Letter June 2005
• Type & Sequence: PR10
• Media Type: D
• Archive: No

MOUNTAIN (0~
~ ~fnumw
LLG West Elk Mine
A Subsidiary ofArch Western Resources, LLC P O Box 591
5174 Highway 133
Somerset, CO 81434
[phone]
Fax [phone]
of Divide area in Exhibit 32B, the Division can see that there are no power lines, waterlines, gas
or oil lines, towers, swimming pools, or tanks in the area.
New Comment: MCC responded that "structures were included in Exhibit 32B and roads on Map 67 of the
Permit Document. " Map 67 shows Minnesota Reservoir as the only structure in the SOD area. Drawings lA
and 1B of Exhibit 32B show stock ponds (which qualify as structures) and other renewable resource lands.
Neither of these drawings meet the certification criteria of Rule 2.10.3(2). A cabin and Cow Camp aze referred
to but do not appeaz to be included on the map.
The permit application document should cleazly identify each structure (man-made feature), provide a brief
description, and be shown on a map that meets the standazds of Rule 2.10. The original DMG comment stands.
MCC Response: MCC has incorporated man-made structures on Map 67.
~~85. Response accepted.
~86. Original Comment: The applicant does commendable job of presenting information in the order
requested by the Rules. However, given the multiple mining areas, multiple coal seams, and the
numerous potential consequences to the various structures and renewable resource lands, it is
somewhat difficult to determine whether all subsidence consequences, mitigation, and monitoring is
adequate and meets the requirements of the Rules. The DMG respec fully suggests that some type of
summary and/or table be included under the subsidence section that clearly describes each type of
structure or renewable resource, the worstpossible consequence of subsidence for each, the subsidence
control or mitigation proposed, and the monitoring necessary for each. DMG is willing to discuss any
other ideas MCC has to bring this important information into focus.
MCC Response: MCC has included a natural resource survey with inventory.
New Comment: The original question stands. MCC's response refers to a natural resources survey. The DMG
response is that a summary discussion and table should be provided to cleazly describe each type of structure or
renewable resource, the predicted impact of subsidence for each, the subsidence control or mitigation proposed,
and the monitoring necessary in each case.
MCC Response; See response to Comment Al.
b~\~ 87. Original Comment: The applicant makes mention of an agreement to monitor water resources above
the area to be mined (Exhibit 19C, and noted on page 2.04.80). Please include this monitoring in the
monitoring plan and indicate that the results will be included in the Annual Hydrology Report.
MCC Respouse: MCC updated the text to include the monitoring.
New Comment: The response was insufficient. The applicant makes mention in Exhibit 19C of a USFS
agreement to monitor water resources above the azea to be mined. Please demonstrate that the DMG permit
• application incorporates the requirements of Exhibit 19C into either the hydrologic monitoring report or the
subsidence report and specify that within the application. It is not clear how the DMG is involved in this
monitoring; please indicate who is ultimately responsible for ensuring that this monitoring is completed and
evaluated. Please provide permit text stating how and when this monitoring will be reported to the DMG.