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TRI -STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233 -0695 303 - 452 -6111 February 17, 2014 Mr. Rob Zuber 1A Environmental Protection Specialist Colorado Division of Reclamation, Mining & Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 RE: Colowyo Coal Company L.P., Mine Permit C -81 -019, Minor Revision No. 131 (MR -131), South Taylor Haul Road Dear Mr. Zuber: Colowyo Coal Company L.P. ( Colowyo) received your adequacy letter for MR -131, dated February 7, 2014. The original adequacy comments (identified in italics) have been incorporated herein for reference to the responses provided. DRMS Item 1: Please revise the spoil grading plan or explain why the years for completion on several parcels on the grading map have been pushed back to year 2024 or later. 1 have discussed this with Tony Tennyson, but am not convinced that these dates make sense in light of Rule 4.13, Contemporaneous Reclamation. Perhaps smaller parcels could be graded at later dates for such things as road corridors and storage areas, but some of the parcels (for example, the 2025 - 2026 parcels) are very large, as much as a half -mile wide. Response: Per a phone conversation between Mr. Rob Zuber and Mr. Tony Tennyson on February 12, 2014, Mr. Tennyson provided additional information on the spoil grading schedule that has been proposed on Map 29. During this conversation, Mr. Tennyson conveyed that the spoil grading areas depicted on Map 29 may not be large areas from a total acreage standpoint; however, they are large from a volume based standpoint. A current example of this is the regrade efforts that have occurred in the north end of West Pit the last three years. Colowyo regraded a very large volume of material during the past three years, but on yearly basis did not regrade many acres. However, once regrading was completed over those years, a large area (acres) was topsoil and seeded. This same concept is depicted on the proposed Map 29. Although the acreage regraded per year may not be very high, the total amount of material moved will be. Colowyo has to take into account how much volume it can move each year and still maintain current production rates and current long term mine plans. The mass balance to close the West Pit is a significant amount of material; therefore, this proposed spoil grading schedule reflects more volume movement per area than acreage regraded per year. Colowyo has tied this schedule to long -term mine plans and equipment, and as proposed, believes this plan complies with Rule 4.13 and current mine plans for the operation. AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER A Touchstone Energy'Cooperative CRAIG STATION ESCALANTE STATION NUCLA STATION P.O. BOX 1307 P.O. BOX 577 P.O. BOX 698 CRAIG, CO 81626 -1307 PREWIrr, NM 87045 NUCLA, CO 81424 -0698 970 - 824 -4411 505 - 972.5200 970 -864 -7316