2010-10-14_REVISION - C1980005 - Laserfiche WebLink

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Permit Revision No.2 Response to Adequacy Comments Page 6 2.05.5 16 The subsection "Postmining Land Use Management" in Tab 13 of the current P.A.P. appears to be somewhat out of date, with particular respect to livestock grazing management. Please provide an updated narrative for inclusion in the PR-2 volume that addresses grazing management within the reduced permit area, with reference to Map Exhibit 13-13.2 "Logical Land Management Units ", which depicts pasture boundaries. Response: We have added Section 2.05.5 Postmining Land Uses, to address grazing management. 17. There appears to be a discrepancy between narrative in the approved permit and narrative on page 2.05.3-2 of the PR-2 volume regarding landowner requests for retention of permanent fencing. The approved P.A.P. states, on page 13-38, that executed landowner requests for permanent fencing will be submitted to the Division for insertion into Appendix 13-1 ]A, upon receipt. The PR-2 narrative states that fences on State of Colorado lands within the permit area have been requested as permanent structures by the land owner and the grazing leaseholder. It does not appear that executed requests for retention of permanent fencing have been provided by the State Land Board, and included in Appendix 13-1 ]A. If a letter requesting retention of permanent fencing depicted on Map 2.05 MI (pasture boundaries and CSU Shrub Plots) has been provided to SCC from the State Land Board, please provide the letter for inclusion in Appendix 13-IIA, and reference the Appendix in the PR-2 text to state that an executed State Land Board request for retention of permanent fencing depicted on Map 2.05 Ml, prior to submittal of application for Phase III bond release. Response: Yes, the discrepancy is a typographic error where Appendix 13-11A should read Appendix 13-12A, Landowner Requests for Permanent Features. Permanent fencing has been included in all the requests for permanent features, except in the case of a specific feature such as a certain road or pond. As far as an executed State Land Board request, the Division (Mike Boulay) was instrumental in assisting in the assembling of these letters since the State Land Board typically addresses the response letters to the Division and not to Seneca. Seneca's copy of Appendix 13-12A contains copies of everything sent to the State Land Board and the response letters provided by DRMS (Mike Boulay). Your concern has not been an issue previously during the Phase I/Phase II bond release efforts or during Seneca's requests for permanent structures in past revisions to the PAP. In an effort to address and alleviate the Division's concern, please refer to Appendix 13-12A in the original PAP. Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 Telephone (970) 276-5217 • FAX (970) 276-5222