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r? <br />PIONEER <br />NATURAL RESOURCES <br />X--ZOI?- Z3Z-?O <br />?,?d-1Je l ? ve red <br />Pioneer Natural Resources USA, Inc. <br />1401 17th Street, Suite 1200 <br />Denver, Colorado 80202 <br />Tel: (303) 298-8100 Fax: (303) 298-7800 <br />Hand-Delivered Via Courier <br />August 30, 2010 <br />REC fRO <br />Kent Gorham SEP 012010 <br />Environmental Protection Specialist <br />Division of Reclamation, Mining and Safety y i ,,?utarnavon, <br />1313 Sherman Street, Room 215 Mining and Sao* <br />Denver, CO 80203 <br />Re: Comments on proposed drilling and coring operations -- NOI for Coal <br />Exploration - New Elk Mine <br />Dear Mr. Gorham: <br />Pioneer Natural Resources USA, Inc. (Pioneer) thanks you for the opportunity to visit <br />with you to discuss our concerns regarding a proposed coal exploration program in an <br />area where Pioneer currently operates coalbed methane (CBM) production wells. <br />Pioneer has reviewed the Notice of Intent (NOI) to explore for coal as proposed by Cline <br />Mining Corp., doing business as New Elk Coal Company, L.L.C. (NECC). Pioneer <br />supports the continued exploration and development of natural resources in the Raton <br />Basin of Colorado. However, Pioneer believes that such operations should be respectful <br />of the environment, community and public health and safety. While reviewing the <br />proposed exploration plan, Pioneer noticed several items which it believes need <br />clarification and possibly modification to be consistent with other rules and practices that <br />apply to drilling coal seams in the Raton Basin. <br />In general Pioneer's concerns are: a) ensuring that coal exploration operations do not <br />compromise public health or safety; b) ensuring that the proposed activities do not cause <br />impacts to water wells and shallow groundwater; and c) ensuring that the disturbance and <br />any impacts associated with coal exploration activities are not confused with Pioneer's <br />CBM operations in the same area. Our specific concerns and comments follow: <br />1. Under rules adopted by the Division's sister agency, the Colorado Oil and Gas <br />Conservation Commission (COGCC), Pioneer is required to test domestic water wells <br />in the vicinity of a proposed CBM well-both before and after drilling. Given that <br />the proposed coal exploration core holes will be similar in depth to CBM wells, <br />Pioneer believes it would be prudent for NECC to implement a similar water well