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telephone of this representative. <br />5. It is stated in Section 6.2.1 "Method" (page 16 of the Notice of Intent) that "about one <br />out of every five holes will be `twinned' and core drilled through the coal". For the <br />purposes of reclamation cost estimating, please revise this sentence to specify that "up <br />to 20 holes will be twinned and core drilled through the coal, with a maximum depth of <br />no more than 180 feet". <br />6. The drilling activities proposed in this Notice of Intent aze described in Section 6.2.1 <br />"Method" (page 16). Please add a third paragraph to Section 6.2.1 to describe whether <br />staging areas, fueling areas, equipment maintenance areas, or lay-down areas will (or <br />will not) be required for the proposed activities. Please be aware that as the Division <br />has determined that the proposed coal exploration activities will "substantially disturb" <br />the natural land surface, compliance with the performance standards of Regulation 4.21 <br />is required by Regulations 2.02.2(3) and 4.21.2(1). As such, staging areas, fueling <br />areas, equipment maintenance azeas, or lay-down areas would have to comply with the <br />applicable requirements of Regulations 4.21.4(4), (5), (6), (7), (9), and (10), and of <br />Regulations 4.04, 4.05.3, 4.05.5, 4.05.6, 4.05.9, and 4.05.13(1). <br />The Notice of Intent states on Page 25 (Section 6.2.2: "Access") that "Individual <br />drilling sites will be accessed by two-track trails and overland travel. Overland travel <br />includes 51 access roads, which total about 48,750 feet, and average approximately 956 <br />feet in length (See Map 1 in pocket, and table 6-2). No blade work or road <br />improvement is anticipated." <br />As the Division has determined that the proposed coal exploration activities will <br />"substantially disturb" the natural land surface, compliance with the applicable <br />requirements of Regulation 4.21 is required. Please therefore revise Section 6.2.2 of the <br />Notice of Intent to add the following pazagraph: <br />"Vehicular travel on other than established graded and surfaced roads will be limited to <br />that absolutely necessary to conduct the exploration. During periods when excessive <br />damage to vegetation or rutting of the land surface could result, travel will be confined <br />to graded and surfaced roads. Any new road used for coal exploration, or any existing <br />road which is `significantly altered' (as defined in Regulation 4.21.4(3)(b) of the <br />Colorado Coal Mining Regulations), will comply with the applicable provisions of <br />Regulation 4.03.3. As stated in Regulation 4.21.4(3)(b), routine maintenance or minor <br />rehabilitation activities, including blading and culvert replacement, do not constitute <br />significant alteration of an existing road." <br />8. As mentioned above, the Division had determined that the proposed coal exploration <br />activities will "substantially disturb" the natural land surface, which in turn requires <br />compliance with the applicable requirements of Regulation 4.21. As such, please revise <br />Section 6.2.1 "Method" of the Notice of Intent to include the following five paragraphs: <br />"If excavations, artificial flat azeas, or embankments aze created during exploration, <br />