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and 4.15.7(3)(iii)(d)). The Division inspected all three reference areas during 2012 and found all <br />three reference areas to be poorly marked. <br />NECC needs to adequately mark the reference areas, at minimum clearly mark the corner limits. <br />Due to recent disturbance of the upland reference area at Parks and Wildlife direction, <br />identification signage is recommended to minimize future disturbance to these sites. Please <br />revise the permit to include a commitment that the reference area will be marked and will be <br />identified with signs. (Rule 2.05.4(2)(e)(vi)) <br />Rule 2.10 Maps and Plans <br />15. The permit area boundary shown on Map 1 does not agree with permit area boundary shown on <br />Map 2. Please assure that permit maps reflect the correct permit boundary. <br />16. Map 2 (dated 2/1/2011) shows a parcel north of most of the State of Colorado lease, but south of <br />Highway 12, with no identifying coal ownership assigned to this parcel (portions of Section 22, <br />23, and 24). Please update Map 2 to illustrate the ownership of the coal under laying this parcel, <br />and update the Legend of Map 2. This parcel closely correlates to the location of the New Elk <br />Mine facilities and portals. <br />17. Disturbance area boundary Map 15, dated 3/8/2006, shows permit area disturbance limits. The <br />RDA limits are included in insert #1. The disturbance limit line is clearly denoted by a dashed <br />line along the east side of the pile, but when it reaches the northern extent it is overlain by either <br />the permit area boundary line or the "DR" line. It is unclear by this Map 15 where the actual <br />disturbance area boundary limits are on the north and west sides of the RDA. Additionally, the <br />disturbance area boundary line extends beyond the edge of the east side of the map along the <br />former rail road grade. An additional insert to Map 15 illustrating the eastern extent of the <br />disturbance area is needed. <br />18. Map 10 (dated 11/08/1999) does not delineate plant communities to the South of the Middle <br />Fork Purgatoire Valley for the New Elk Mine. Please provide an acceptable mapping of the <br />surface communities in the areas of the permit located south of the mine facilities area. Please <br />include areas disturbed by the Apache Canyon air shafts (Rule 2.04.10(1)). <br />19. Rule 4.07.3(3) requires the location of drill holes to be accurately spotted on a topographic map. <br />Please provide an updated map accurately depicting all drill holes. <br />20. Information regarding boreholes, slurry wells, groundwater monitoring wells, and other <br />drillholes are found in several locations throughout the permit: Table 9, Table 27, Section 2.05 <br />page 5e, and 90f, and Exhibit 08. Please summarize all holes, and their status (sealed, <br />monitoring well, completion depth, etc.) in one table. <br />12 <br />