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As a current market does not exist for the Williams Fork reserves, it would be premature to develop and provide <br />detailed mining plans and sequencing for future operations. The Northwest Colorado coal market is, however, <br />dvnainic, with reasonable potential for changes in local and regional market conditions, as evidenced by <br />significant recent activity, including re- permitting of the Trapper Mine operations, extensive upgrades to the <br />Craig Station, installation of a rail spur to the Hayden Station, and the recent sale of the Colowyo Mine property <br />to Western Fuels. <br />Given the remaining reserves, existing valid leases, and usable infrastructure that exist at the Williams Fork <br />property, the additional identified reserves which could potentially be accessed from the Williams Fork Mines, <br />and changing conditions in the Northwest Colorado coal market, a commitment to pursue Permanent Cessation <br />and reclamation at this time would be inappropriate and short- sighted. <br />MCM has met the applicable regulatory requirements for successive right of renewal, and there are no <br />provisions in the CMLRB regulations that place specific time limits on "Temporary Cessation ". While, as noted <br />in the CDRMS comments, there are requirements for "Contemporaneous Reclamation ", MCM has taken a pro- <br />active and responsible approach in reclaiming any facilities not needed or suitable for fiiture operations, and has <br />effectively monitored and maintained all other remaining facilities. <br />2. Permit page 2.05 -4 contains details regarding the `Mine Sequence" at the Williams Fork Mines. This <br />section of the permit contains specific dates, timing and permit term information that are out of date. <br />Additionally; since the mine has been in Temporary Cessation since 1995 and the mine sequence <br />information was last updated in 2004, the proposed mining discussed in this section may not be correct.. <br />Please review the dates, timing and permitterm information contained in the "Mine Sequence" section of <br />the permit, beginning on page 2.05 -4 and update as necessary. Please update the proposed mining to <br />reflect the current plans for the Williams Fork Mines. If no additional mining is proposed, please <br />provide a justification,for keeping the mine and facilities idle and not reclaiming the site. <br />Response: The Permit description of mine sequencing and timing has been reviewed and revised; as <br />appropriate, to reflect current and reasonably foreseeable near -term conditions and plans. Copies of the revised <br />Permit discussion accompany these responses for replacement in the PAP. <br />3. Permit page 205 -7 contains a discussion of the drilling activities and planned fictur°e monitoring of wells <br />94 -001 and 95 -14. Based on a review of current drill holes and hydrological monitoring sites, the status of' <br />these wells is unclear. Hole 95 -14 is shown on Map 11 _Hydrologic Monitoring Program Location Map <br />but it is not sampled, included in the Annual Hydrology Report or shown on AHR Figure 2 — Hydrologic <br />Monitoring Program Location Map. The Division could f nd no other reference to hole 94 -001. Please <br />review the information on page 2.05 -7 for holes 94 -001 and 95 -14 and update their status as necessary. <br />Please provide the Division with a discussion of proposed well 95 -14 and its possible inclusion in the <br />hydrologic monitoring plan. <br />Response: The specific Permit text discussion relating to the referenced swells has been reviewed and revised to <br />clarify and update the status and use of these swells. Copies of the revised Permit discussion accompany these <br />responses for replacement in the PAP. <br />4. Per °mit page 2.05 -9 discusses the Multiple Services Building at the Mine 5A portals. Luring 2010 and early <br />2011 MCM has removed oil tanks and barrels of waste oil and other products. Please update the status <br />and reclamation activities of the Multiple Services Building on permit page 2.05 -9. <br />Response: The specific Permit text description of the Multi- Services Building has been reviewed and updated <br />to reflect recent site activities. Copies of the revised Pen-lilt discussion accompany these responses for <br />replacement in the PAP. <br />2 <br />