PERMFILE130837

• Permit No: X200722900
• IBM Index Class Name: Permit File
• Doc Date: 7/6/2007
• Doc Name: Adequacy Letter
• From: DRMS
• To: Colorado Coal Resources, LLC
• Media Type: D
• Archive: No

"Vehicular travel on other than established graded and surface roads will
be limited to that absolutely necessazy to conduct the exploration. Travel
will be confined to graded and surfaced roads during periods when
excessive damage to vegetation or rutting of the land surface could result."
6. In accordance with the requirements of Regulations 2.02.2(2)(f) and 4.21.4(5), please modify
the text of the NOI to include the following statement:
"Prior to earth-moving or excavations of any type, the A and B horizons
will be salvaged and stored in area that will be undisturbed and not
subject to excessive wind or water erosion. The underlying subsoil
materials will, if necessary, be salvaged and stored in an azea separate
from A and B horizon materials. Immediately upon cessation of operations,
the subsoil will be replaced, with the surface left in a roughened condition.
The A and B horizons will then be replaced over the subsoil material."
7. In accordance with the requirements of Regulations 2.02.2(2)(f) and 4.21.4(4), please modify
the text of the NOI to include the following statement:
"Excavations, artificial flat areas, and embankments created during
exploration will be returned to their approximate original contour promptly
after such features are no longer need for coal exploration."
8. As mentioned previously in this letter, the Division has calculated a reclamation cost estimate
for this NOI. This cost estimate reflects certain telephone conversations held recently between
the Division and representatives of Colorado Coal Resources LLC. Per these conversations,
Colorado Coal Resources LLC has stated that, contrazy to language in the NOI, it does not
intend to twin any of the primary 11 exploration drill holes (CCU-001 through CCU-011)
without first submitting to the Division for approval an amendment to the NOI to conduct the
twinning. The cost estimate for the NOI reflects this intent, and therefore does not contain
reclamation costs for twinned holes. In accordance with the requirements of Regulations
2.02.2(2)(8) and 3.05.2, please therefore revise the NOI to indicate that Colorado Coal
Resources LLC will not twin any holes approved under the NOI until an application for an
amendment to the NOI for twinning is submitted to and approved by the Division.
9. It is stated on the second page of the June 8, 2007, cover letter that "CCR has developed the
reclamation see mixture in consultation with CDOW; however, for explorations on agricultural
lands, the disturbance will be reseeded as requested by the landowner." It is further stated on
Page 10 of the NOI that "Disturbed areas will be reseeded to stabilize the surface and control
erosion using the following seed mix, or a mixture developed in consultation with the
appropriate landowner or as specified by the CDOW (for areas with state surface ownership)."
As some of the proposed drill holes lie on property owned by three separate surface owners
("Hockett", "Williams", and "Zulian"), these statements suggest that up to six different seed
mixes could be used in the revegetation of the disturbed areas. Only one seed mix was