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Attachment 20 -2 of the permit application package. SCC plans to retain stock ponds and <br />sedimentation ponds as permanent structures; these permanent sediment ponds and stock ponds <br />are included in the SL -4 bond release application and were required to comply with the <br />permanent impoundment requirement outlined in Rule 4.05.9(13). The requested SL -4 bond <br />release area encompassed the following impoundments: sediment ponds 005, 006, 009, 015, 016 <br />and 017; stock ponds T -2, 3, 5, 18, 20, 22, 24, 26 and 27. In order to comply with Rule <br />4.05.9(13), SCC has included in their permit Attachment 20 -2.1 and 20 -2.2 of Tab 20. <br />Attachment 20 -2.1 include letters from the surface owners where the ponds are located indicating <br />that they desire to leave these structures as permanent features. Attachment 20 -2.2 includes a <br />permanent impoundment demonstration for each impoundment which addresses the <br />requirements of Rule 4.05.9(13) and supporting documentation such as water quality analysis <br />and SEO approval forms. At the time of the submittal of the SL -4 bond release application, SCC <br />had not submitted all of the required information /documentation for these impoundments to <br />remain as permanent ponds in accordance with Rule 4.05.9(13). This issue was cited as an <br />adequacy review item. Please see the background information section of this document for <br />detailed information about this issue. <br />Roads <br />A number of existing roads within the permit area have been approved or proposed as permanent <br />structures for the postmining land use, to allow for access through the permit area by multiple <br />private landowners, and to provide access to various portions of the permit area to facilitate <br />postmining use and management. These roads encompassed in the SL -4 bond release area are <br />shown on Figures 1(a -d) of this document. Landowner requests for permanent road retention, <br />rationale and justification for retention, and summary of permanent road specifications are found <br />in Tab 20, Attachment 20 -2 of the permit and the locations are shown on Exhibit 20 -2, Post <br />Mining Topography. These roads are also depicted on Exhibit B (Phase I Bond Release Post - <br />mine Topography and Drainage) of the SL -4 application. Road design plans, postmining <br />criteria, and As -Built drawings are provided in Tab 13 of the permit. <br />Haul roads or haul road segments to be retained for permanent retention as access roads were <br />modified for postmining use by eliminating MSHA berms, reducing travel width to 28 feet <br />(Routt County Road 53C) or 20 feet (all other permanent access roads), and grading and seeding <br />roadsides and graded slopes. Several light use roads have been proposed for permanent retention <br />as ranch roads mostly to replace ranch road segments that were in place on the landscape prior to <br />mining. Light -use roads are generally reduced to twelve feet in width, and graded and seeded on <br />the roadsides. <br />III. OBSERVATIONS AND FINDINGS <br />The following discussion of observations and findings focuses on the results of backfilling and <br />grading work, permanent impoundment and road compliance and drainage reestablishment in the <br />SL -4 bond release area; and the reassessment of areas excluded from the SL -3 bond release request <br />Page 12 of 18 <br />