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Page 7 of 9 <br />design runs for all mine disturbed area ponds, ditches and culverts, appears on page 2 of Appendix <br />2.05.3(4) -1. However, there do not appear to be stated justifications for the use of a curve number of 79 for <br />culverts C -6A and C -6B and the use of a curve number of 89 for culvert C -12. The Division requests that the <br />appropriate section of the permit application be updated to detail the justifications for using the curve <br />numbers of 79 and 89 in these three culvert designs. <br />The Division has no further concerns. Page 3 of Section 2.05.3(4) was revised in the November 29, 2011 <br />submittal. <br />25. A) On page 8 of Section 2.05.3(4), WFC has requested a small area exemption designation for the <br />topsoil berm that will be constructed in advance of stripping. However, a small area exemption is defined <br />under Rule 4.05.2(3) and requires a demonstration that the area will meet sediment limits. This does not <br />appear to apply in this situation. In order to avoid any confusion, please revise the discussion on page 8 <br />by using a term other than a small area exemption when referring to this berm. <br />The Division has no further concerns. The small area exemption language was removed from page 8 in <br />the November 29, 2011 submittal. <br />2.05.6(3) — Protection of hydrologic balance <br />2. In the submittal dated May 26, 2011, Western Fuels expanded on the discussion concerning stream buffer <br />zones. However, the May 26, 2011 cover letter response to this question states that mining will affect the <br />stream buffer zone along Meehan Draw and that the text was revised to describe this situation. However, in <br />the expanded discussion on page 7 of Section 2.05.6(3), it is stated that no stream buffer zones will be <br />affected by mining. Please explain this apparent discrepancy <br />The Division has no further concerns. Page 7 of Section 2.05.6(3) was revised in the submittal dated <br />November 29, 2011. <br />3. In the submittal dated May 26, 2011, Western Fuels provided the requested calculations in Table 2.05.6(3)- <br />2 on page 29 of Section 2.05.6(3). However, no data were presented for Coal Creek Canyon. Please explain. <br />The Division has no further concerns. Table 2.05.6(3) -2 was revised in the November 29, 2011 submittal. <br />5. In the second to last paragraph on page 8 of Section 2.05.6(3), it is stated that WFC will file for an <br />augmentation plan with the Water Court. Please provide a copy of the augmentation plan to the Division <br />when it is approved and reference the location of the plan on page 8. <br />On page 8 of Section 2.05.6(3) in the submittal dated May 26, 2011, Western Fuels stated that they have <br />applied to the Water Court to confirm its conditional water rights and, then, to have the conditional water <br />rights become absolute before mining begins. The approved plan will be provided to the Division and placed <br />in Appendix 2.05.6(3) -lc. <br />6. In the top paragraph on page 9 of Section 2.05.6(3), it is stated that WFC plans to operate a Substitute <br />Water Supply Plan. Please provide a copy of the plan to the Division when it is obtained and reference the <br />location of the plan on page 9. <br />On page 9 of Section 2.05.6(3) in the submittal dated May 26, 2011, Western Fuels stated that they have <br />applied for the Substitute Water Supply Plan and, as for the Water Augmentation Plan, a copy will be sent to <br />the Division and inserted into Appendix 2.05.6(3) -lc. <br />