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18. As per Rule 4.05.9 9(d), if these ponds are expected to be permanent, please <br />demonstrate that no diminution of water quality or quantity to water right holders <br />will ensue. <br />Trapper Response to Comment 18: See above comment. The water rights demonstration would be made <br />at the time it were decided to retain ponds as permanent. <br />19. Without a mine plan DRMS finds it problematic to adequately assess the models <br />provided for the additional sediment ponds. Please provide subwatershed <br />delineations for expected disturbed and undisturbed areas. <br />Trapper Response to Comment 19: An enclosed map that delineates subwatershed characteristics is <br />included with the enclosed Appendix Q SEDCAD runs for Deacon, Deal and Jeffway sediment ponds. In <br />the absence of a definitive mine plan for the PR -7 Expansion Area, this map illustrates the engineering <br />assumption that all the lands within the current coal lease area will be disturbed at the same time. This <br />assumption insures that all ponds will be overdesigned relative to future needed pond capacities since this <br />amount of watershed disturbance would never occur at any one point in time. <br />20. Modelling for the Deal channel lacks a freeboard value. This value is required as <br />per Rule 4.05.3(7)(b) <br />Trapper Response to Comment 20: This information has been included in the enclosed revised SEDCAD <br />model information. <br />21. Modeling for Deacon Ponds does not differentiate between pond 1 and pond 2. <br />Trapper Response to Comment 21: This information has been included in the enclosed revised SEDCAD <br />model information. <br />Rule 2.05.3(5) Topsoil <br />This aspect of the Rules is adequately addressed. <br />Rule 2.05.4 Reclamation Plan <br />This aspect of the Rules is adequately addressed. <br />Rule 2.05.4(2)(b) — The Division has yet to compile a reclamation cost estimate (RCE) <br />associated with the new sedimentation ponds. This RCE will be completed once all <br />adequacy items that may include any changes to the proposed ponds are addressed. <br />Rule 2.05.5 Post Mining Land Use <br />This aspect of the Rules is adequately addressed in the permit. <br />Rule 2.05.6 Mitigation of Impacts <br />This aspect of the rules is adequately addressed. <br />