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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 />September 21, 2011 <br />Roy Karo <br />Seneca Coal Company, LLC <br />P.O. Box 670 <br />Hayden, CO 81639 <br />RE: Seneca II Mine (Permit C- 1980 -005) <br />Permit Renewal No. 6 (RN -6) Adequacy Review <br />Dear Mr. Karo, <br />The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed Seneca Coal <br />Company, LLCs Permit Renewal, RN -6. Please respond to the following adequacy comments as <br />necessary: <br />1. Based on a reviewed the ownership and control section of the currently approved permit <br />application package for the Seneca II Mine, comparing the section with the current information <br />in the Applicant Violator System (AVS), there are numerous discrepancies that will need to be <br />addressed by Seneca Coal Company, LLC. Please address the discrepancies listed below: <br />Office of <br />Mined Land Reclamation <br />Peabody Energy Corporation <br />STATE OF COLORADO <br />COLORADO <br />D I V I S I O N O F <br />RECLAMATION <br />MINING <br />— &— <br />SAFETY <br />John Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />a. Douglas D Loucks is listed in AVS as an Assistant Treasurer (beginning 12/15/2010), <br />but is not listed in the currently approved permit application package. Please either <br />provide an end date for Douglas D Loucks as Assistant Treasurer or update the list of <br />officers in the permit application package. <br />b. Carey J Dubois is listed in AVS as Vice President (beginning 12/15/2010) and <br />Treasurer (beginning 12/15/2010), but is not listed in the currently approved permit <br />application package. Please either provide an end date for Carey J Dubois as Vice <br />President and Treasurer or update the list of officers in the permit application package. <br />c. Jeane Hull is listed in AVS as Executive Vice President, beginning March 16, 2011, but <br />not listed in the currently approved permit application package. Please either provide <br />an end date for Jeane Hull as Executive Vice President or update the list of officers in <br />the permit application package. <br />d. Frederick D. Palmer is listed in the currently approved permit application package as a <br />Senior Vice President, but was end dated from this position by AVS on May 6, 2005. <br />Please verify whether Frederick D. Palmer remains as Senior Vice President of Peabody <br />Energy Corporation. <br />Office of <br />Denver • Grand Junction • Durango Active and Inactive Mines <br />