2010-09-15_PERMIT FILE - X201023200

• Permit No: X201023200
• IBM Index Class Name: PERMIT FILE
• Doc Date: 9/15/2010
• Doc Name: Response to Comments
• From: DRMS
• To: Pioneer Natural Resources USA, Inc.
• Email Name: KAG
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203 COLORADO

Phone: [phone] DIVISION OF
RECLAMATION
FAX: [phone] MINING

SAFETY
September 15, 2010
Bill Ritter, Jr.
Governor
Gerald Jacob, Ph. D.
Mike King
Environmental Advisor Executive Director
Pioneer Natural Resources USA, Inc. Loretta E. Pineda
1401 17th Street Suite 1200 Director
Denver CO 80202
Re: Response to comments on NOI X-2010-232-00
Dear Mr. Jacob:
We have reviewed your letter of August 30, 2010 pertaining to New Elk Coal Company (NECC)
Coal Exploration Notice of Intent (NOI) X-2010-232-00. This NOI was approved by the Division
of Reclamation, Mining and Safety (DRMS; the Division) on August 27, 2010. We appreciate
your letter, and have forwarded a copy to NECC Mine Manager Ron Thompson. Our response to
the comments in your letter follows, with your original concerns paraphrased for reference.
Testing of nearby water wells before and after exploration operations.
While coal exploration holes proposed under this NOI may be similar in depth to nearby
existing or proposed coal bed methane production wells, DRMS does not believe sufficient
cause exists to warrant testing of water wells before and after coring operations approved
under this NOI. The activities approved under this NOI are expected to be limited in time
and scope, with minimal disruption to the overburden and the coal seams drilled and cored.
Should NECC choose to nevertheless follow your suggestions, this will be up to them.
2. Coal exploration drilling releasing large amounts of methane at the surface.
Our Rules regulating coal exploration and reclamation activities do not require persons
proposing such activities to describe in their NOI applications how venting of any potential
methane that may be encountered will occur. Coal exploration activities approved under
this NOI are nevertheless not expected to release large amounts of methane at the surface,
as recent NECC experience with a core-hole drilled within 200 feet of an active coal-bed
methane well did not result in large amounts of methane at the core-hole site itself. Should
NECC choose to nevertheless follow your suggestions, this will be up to them.
3. Providing notice to individual landowners.
Our Rules regulating coal exploration and reclamation activities do not require persons
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