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® MWH MONTGOMERYWATSON HARZA January 29, 2002 Linda M. Gross, Field Manager Bureau of Land Management - ICremmhng Field Office 11 ] 6 Pazk Avenue 1Cretnmling, Colorado 80459 Re: Kerr Coal Company -Borehole Reclamation Plan Dear Ms. Gross: iiiiiiiiiiiniii iii 999 RECEIVED 1AN 3 ~ 2QU2 Division of Minerals andGeologY This letter, provided by MWH on behalf of Kerr Coal Company (Kerr), responds to your letters dated August 12, 2001 and December 10, 2001 pertaining to drillhole and well abandonment on Coal Exploration License C-28056 and Coal Lease C-22777. This letter also addresses Stipulations 22 and 23 (copies attached for reference) to the approved Colorado Division of Iolinerals & Geology (CDMG) Dtining and Reclamation Plan and assouated permit. Pursuant to CDMG Stipulation 22, research of lierr's archives resulted in additional information on borehole locations, designations, completion information, and history. This additional information (summarized by the attached Borehole Information Update Summary) has been incorporated into the supporting tables for the previously submitted (1/3/00, updated 9/15/00) borehole reclamation plan. The originally submitted Borehole Reclamation Plan remains valid with minor modifications reflecting the additional information recently obtained and updates to reflect cuaent scams and timing. A copy of the updated Borehole Reclamation Plan is attached for reference. The BLM's original correspondence (8/12/01) on this matter indicates a tazget date of August 12, 2002 for completion of borehole reclamation activities. More recent BLM correspondence (12/10/01) and CDMG Stipulation 23 have moved this date up significantly to May 31, 2002. Kerr has significant concerns relative to completion of the borehole reclamation activities by this eazlier date. Ground conditions in North Park are typically wet and muddy well into the spring, effectively limiting field operations. Based on experience in this azea, it is not reasonable to expect acceptable access conditions until late May or early June. Since most of the boreholes were drilled over fifteen yeazs ago, both drill-sites and access have stabilized with vegetation. Trying to access these sites before the ground dries out would result in significant surface damage and very difficult Field operations. Kerr, therefore, requests that the target completion date for borehole reclamation of August 12, 2002 be retained as originally proposed. Kerr plans to complete the field reconnaissance portion of the borehole reclamation plan as soon as ground conditions allow this spring. Borehole abandonment and reclamation activities would then be initiated in Jurte or]uly and completed prior to the August 12, 2002 completion date. All borehole reclamation activities will be conducted in accordance with the accompanying updated Borehole Reclamation Plan. The primary outstanding question relative to the proposed borehole reclamation program is retention of some of the boreholes/wells for potential future beneficial use. Kerr has attempted to address this question in the Borehole Reclamation Plan and supporting P.G. Box 77401fi Tel: 970 979 6260 Celmenn_c Irmo velrve Prarecls antl Solutions Worldwrtle 1475 Pine Grove Road, Suite 109 Fax 570 679 9048 /% S[eem6oat Springs, Colorado 60477