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MOFFAT COUNTY MINING - WILLIAMS FORK MINES PERMIT C -81 -044 2011 MID-TERM REVIEW RESPONSES 1. The currently approved permit contains several mine plan reaps.. These maps include Map 22 — Eagle No. 6 E -Seam Workings Life of Mine; Map 23 Eagle No. 5 Mine F -Seam Workings 5 -Year Projection and Map 24 Eagle No. 5 E -Seam Workings 5 -Year Projection. Map 22 shows areas that were mined in the E -seam, with projected completion dates of November 1995. There was additional development work of the north mains shown and numerous proposed panels to the north with no projected mining dates given. Map 23 shows a large room and pillar mining area in the F -seam that has been completed and several longwall panels that were schedzded to be completed by November 1989 (although mining at the site ceased in 1955). There is no additional mining projected in the F -seam beyond 1989. Map 24 shows longwall panels that were completed in the E -seam through May 1994 and one longwall panel that has been developed, with projected mining in 1996 and 1997. There are also several proposed longwall panels with no projected mining dates given. There has been no raining at the Williams Fork Mines since late 1995 and there is no proposed mining in the future. Additionally, all of the portals at the Williams Fork Mines have been sealed and all of the portal areas, with the exception of the Mine No 5A portals, have been backfilled and regraded.` The Mine No. 5A portal was temporarily ;sealed, to prevent access by the public; and could be reopened to access both the E -Seam and the F -Seam. Based on the above discussion it is apparent that the Williams Fork Mines have sat idle for the past 16 years, with no coal mining activities taking place. While MCM has talked about the possibility that raining will be reinitiated in the frtture, no proposed plans have been submitted: Rule 4.13 requires the contemporaneous reclamation of mine related disturbances following the commencement of mining activities. It is the Division's opinion that mining has ceased at the Williams Fork Mines at this time. Please provide the Division with a Permit Revision containing a current mine plan and timetable for the restarting of mining operations at the Williams Fork Mines or provide the Division with a detailed reclamation plan and timetable for the commencement and final reclamation of the site, to begin in April 2012. The Permit Revision for the mine plan or reclamation plan must be submitted no later than 30 September 2011 as further requested in Question 12 below: Response: It is important to note that the Williams Fork Mines suspended operations in 1995, due to a combination of market, operational, and other factors. While market conditions for the associated coal reserve have not improved enough in the interim to justify reopening the Mine, significant additional mineable reserves remain; which could be readily developed if market conditions were favorable. MCM has also continued to pay significant advance payments in lieu of royalties in order to keep our surface and mineral leases active for the Williams Fork Mines. There is also significant mine infrastructure (rail spur, coal handling facilities, water . and wastewater systems, mine portal structures, and shop/warehouse facilities) remaining, which could be effectively utilized or upgraded to expedite and facilitate any future mine development and operations. Moffat County Mining, LLC (MCM) has been diligent in maintaining the Williams Fork Mines property since the time it went into Temporary Cessation, as evidenced by our ongoing maintenance and monitoring efforts, and the lack of any violations since 2002. We have also maintained all required permits through timely filings and compliance with the applicable permit terms, and have taken a pro - active approach in assessing and reclaiming any facilities for which there is no longer reasonable potential for future use. The referenced maps provide valuable information on the extent and sequence of previous historic mining operations, identify those mine workings which may be utilized to access future reserves, and outline the reserves which could be initialb, developed from existing mine workings. Extensive previous exploration drilling has also identified additional coal reserves to the north and west which could potentially be accessed from the Williams Fork Mines. I