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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />August 26, 2010 <br />Roy Karo <br />Seneca Coal Company, LLC <br />37796 Routt County Road 53 <br />P.O. Box 670 <br />Hayden CO 81639 <br />RE: Seneca II Mine (Permit No. C-1980-005) <br />Permit Revision Application No. 2 (PR-2) <br />Reduced Permit Area - Preliminary Adequacy Review <br />Dear Mr. Karo: <br />COLORADO <br />DIVISION OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Govemor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />We have completed a preliminary adequacy review of your application for Permit Revision No. 2 (PR- <br />2), and have the following questions and comments regarding the application. <br />Organizational Comments <br />1. The PR-2 application was submitted as a "stand alone" volume, to describe and delineate the <br />proposed reduced permit area and to incorporate associated changes into the Seneca II permit <br />application package P.A.P. Certain sections (tabs) of the existing P.A.P. will be partly or <br />wholly revised and superseded by maps and text included in the PR-2 volume. Other tabs will <br />be unaffected, with the exception that the permit boundary on all maps in the current P.A.P. <br />(Volumes 1 through 13) will be superseded by the permit boundary described in PR-2 and <br />depicted on PR-2 Maps. There would seem to be potential for confusion to arise in the future, <br />with respect to operational or reclamation plan requirements that are addressed in both the PR-2 <br />volume, as well as sections of the currently approved P.A.P. We believe the PR-2 application <br />could be better integrated into the P.A.P., and that potential for future uncertainties could be <br />reduced by the following steps: <br />• Designate the PR-2 Volume as Volume 14 (Permit Revision No. 2, Reduced Permit Area), <br />and provide the appropriate cover sheet revisions for the volume. <br />Office of Office of