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Mr. Ross Gubka, P.E. <br />Western Fuels-Colorado <br />December 11, 2007 <br />Page 5 <br />baying, fertilization, etc., that will be conducted to comply with Rules <br />4.15.7(3)(d) "management in accordance with approved postmining land <br />use" and 4.15.7(3)(f) "management consistent with reclaimed area during <br />bond release sample years". <br />7. The procedure for calculating an acreage weighted soil type based adjustment <br />factor for a reclaimed block is described in the narrative on amended page (e)-31 <br />and calculation of the weighted average adjustment factor for the reference area is <br />presented on the same page, in Table (e)-3. The procedure for using a reclaimed <br />area adjustment factor to modify the reference area (production) value is also <br />described, but the description of the procedure does not completely reflect our <br />understanding of how the factor would be used, and does not appear to be entirely <br />correct. Please consider the following language to replace the final sentence <br />on page (e)-31: <br />This weighted average adjustment factor is then divided by the <br />reference area weighted average adjustment factor (1. 022), and <br />the resulting value is multiplied by the reference area production <br />sample mean to obtain the production standard for that <br />particular reclaimed block For the purpose of statistical <br />comparisons, the reference area production sample standard <br />deviation must be multiplied by the same value as the sample <br />mean. <br />8. The first sentence at the top of amended page (e)-34 seems to be a re-statement of <br />the adjustment procedure in different words, and is somewhat unclear. If the <br />wording recommended in Item 8 above is accepted, the sentence could be deleted <br />with no loss of information. Please delete or amend the first sentence on <br />amended page (e)-34, as appropriate to clarify the reference area production <br />adjustment procedure. <br />9. There appear to be some labeling errors on map 3.02.2-10 and 3.02.2-11, with <br />respect to soil types within the proposed irrigated pasture reference area <br />boundary. Specifically, the 0.22 and 0.24 acre parcels in the northern portion of <br />the reference area are located within the Soil Type 81 boundary, but are labeled as <br />"Soil 77". Please amend Maps 3.02.2-10 and 3.02.2-11 (as well as the copy of <br />Map 3.02.2-11 in Attachment 2.04A(2)(e)-4) to correct the apparent labeling <br />errors. <br />10. As noted on amended page (e)-32, new Attachment 2.05.4(2)(e)-5 provides cover <br />and production data from the 2007 sampling of the proposed irrigated pasture <br />reference area. The data are presented in the form of worksheets and statistical <br />summary tables, but do not include "final report type" cover and production <br />summary tables. Please include "fmal report type" summary tables for cover <br />and production. The cover table should be organized by life form category