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Lemorandum <br />To: Janet Binns <br />From: Don MacDonald (Coors Energy Company <br />Date: 4/23/2010 <br />Re: Keenesburg 2009 Annual Reclamation Reports - Response to 4/1/2010 <br />Coors Energy Company (CEC) is using this format to respond to comments issued 4/1/2010 <br />following DRMS (Division) review of the 2009 ARR. <br />1. Comment: <br />"Please provide an explanation to the Division as to the variance of the seeding rate of the <br />species in question." <br />Response: <br />Seeding rate discrepancies have been discussed verbally with representatives of the Division. <br />Following this conversation, the Division indicated that they would further examine files and <br />records relative to seed species and corresponding seeding rates. <br />2. Comment: <br />"Please explain the discrepancy in volumes expected to remain in the long-term spoil pile and the <br />amount reported in the 2009 ARR." <br />Response: In early 2009, CEC compiled data to support a subsequent (June 2009) submittal of a <br />technical revision (TR-40), seeking to revise the final topography of the Long Term Spoil Pile <br />(LTSP) area, and thus to increase the material available for the reclamation of B-Pit. At that <br />time, the revised volume of spoil material was calculated over 51 acres, and was estimated to be <br />367,400 bank cubic yards (BCY). The volume of spoil removed from the LTSP during 2009 was <br />calculated to be 6,945 BCY, as was reported in the 2009 ARR. The calculation was completed <br />using CAD techniques, and was based on the most recent (October 2009) aerial photographic <br />mapping of the site, then comparing the 2009 topography to the TR-40 design topography. The <br />2009 CAD calculation included only those areas of the LTSP area that were known to have been <br />used to remove soil for reclamation work in B-Pit, and not the entire LTSP area. <br />As indicated, the Division has noted a discrepancy of 6,437 BCY in the volume of spoil <br />calculated as being removed from the LTSP area. This would equate to approximately 1.7%, or <br />less than one inch of soil over the entire LTSP area. The discrepancy could occur for many <br />different reasons, including: <br />a) Very slight topographic mapping variations from one year to the next.