2018-09-04_GENERAL DOCUMENTS - C1980007

• Permit No: C1980007
• IBM Index Class Name: General Documents
• Doc Date: 9/4/2018
• Doc Name: Proposed Decision and Findings of Compliance
• From: DRMS
• To: CAM Mining, LLC
• Permit Index Doc Type: Findings
• Email Name: LDS
• Media Type: D
• Archive: No

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15. The Division finds that the activities proposed by the applicant would not affect the
continued existence of endangered or threatened species or result in the destruction or
adverse modification of their critical habitats (2.07.6(2)(n)).

16. The Division has contacted the OSM Fees Branch. As of the date of these findings, MCC
is current in the payment of reclamation fees required by 30 CFR Chapter VII, subchapter
R [2.07.6(2)(O)]. MCC's compliance information was verified through the use of the AVS
on August 24, 2018.

Section B - Rule 4

I. Roads - Rule 4.03

A. Haul Roads

1. No roads on the West Elk Mine site are specifically designated or utilized as
only haul roads. A majority of the roads are considered both haul and access
roads. They are primarily used as access roads, but occasionally coal or coal
mine waste is hauled across the road. This classification includes the
following roads:

Main Haul/Access Road - from Highway 133 to the intersection with the
Upper Mine haul/access road;
Upper Mine Haul/Access Road – from the Main haul/access road to the Portal
access road;
Middle Mine Haul/Access Road – from the Main haul/access road to the
breaker building
Sylvester Gulch Haul/Access Road – from the Main haul/access road to the
Shaft 1 and 2 areas
Silo Haul/Access Road – around the silos and lower stack tube pad

As coal or coal mine waste may be hauled on the above roads, all of the roads
have been designed, constructed and certified as haul roads. As-built
certifications are provided in Exhibit 8A of the permit document. A discussion
of the haul/access roads is found in Section 2.05.3 in Volume 1 of the permit
document. The designs are in compliance with Rules 2.05.3 and 4.03.1.
Haul/access roads are shown on Map 53 and 53B.

2. With the exception of a portion of the Sylvester Gulch Haul/Access Road,
these haul/access roads will be reclaimed upon closure of the mine when the
roads are no longer necessary. A portion of the Sylvester Gulch Haul/Access
Road (from the Main haul/access road to the Sylvester Gulch fan) will be
reduced to a light use road and will provide access to the fan site and areas to
the south.

B. Access Roads