2024-03-12_REVISION - C1981022 (18)

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• Somerset Cemetery Road (also referred to as West Valley Haul Road) • Sanborn Creek Road (also referred to as East Yard Haul Road) • Elk Creek Road The text also states that, of the other minor roads: "Any pre-law roads or roads required for ongoing access will be retained". This process has been well documented through the findings of SL-2 and SL-3. With respect to powerlines, the text of the reclamation plan is a little vague in places. It is clear that those powerlines, and associated access roads and substations, owned by Delta-Montrose Electric Association (DMEA)will be retained, and that their ongoing maintenance and eventual reclamation is the responsibility of DMEA. The text goes on to state: Local electric distribution lines in facilities areas and between the main facilities area and the Bear Creek and Hubbard Creek facilities areas are owned by OMI and will be removed on completion and cessation of all mine activities. A powerline construction/access road was constructed by US Steel in conjunction with the Bear Creek—Hubbard Creek powerline. This powerline and powerline access road have not been in use since the Somerset Mine was idled in 1986 They may, however, be utilized in the future if the Bear Creek or Hubbard Creek facilities are developed to support mining in the Elk Creek Mine. The BLM and an adjacent landowner have specifically requested that this powerline road be retained for access, so this road will not be reclaimed. In order to be eligible for bond release it will first be necessary to clarify the ownership and ongoing use of each of the remaining powerlines in the text of the reclamation plan. (k) Sedimentation Ponds and Post-mining Drainages (Page 2.05-66) The reclamation plan states that sedimentation ponds will be removed, unless separately approved in the future as permanent impoundments to support the post-mining land use. No permanent ponds are identified in the reclamation plan, although, as noted in item (e), above, Map 2.05-M8 shows the retention of Pond B, and the status of Ponds A and B is unclear on Map 2.05-M6. In order to be eligible for bond release, sedimentation ponds should be reclaimed, in accordance with the reclamation plan, after the disturbed area reporting to them has received at least Phase 11 bond release. If a pond is to be retained in support of an alternative post-mining land use, it should be specified in the reclamation plan and a permanent pond demonstration should be submitted to the Division in the form of a revision to the permit. The affected segments of Bear Creek, Hubbard Creek and Elk Creek have been reconstructed, and those in Bear Creek and Hubbard Creek have received Phase III bond release. As was stated in the SL-1 findings: 17