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Ann Baldridge 2.04.12 Prime Farmland Investigation - 2 - February 4, 1985 The applicant indicates on page 9-20, Volume V, that no prime farmland exists in the mine area or the tie across haul road corridor area. This is confirmed by letters from the Steamboat Springs S.C.S. district office (contained in Appendix 9-S, Volume V), stating that "Routt County and specifically the area included in the Routt County Soil Survey area does not have any prime farm land". As such, the applicant will need to submit with the permit application a request for a negative determination which concludes that the land meets one of the criteria of 2.04.12(2). 2.05.2 Operations Plan - Life of Mine No comments. 2.05.3(5) Operations Plan - Topsoil Removal and Storage No comments. This section appears adequate. 2.05.4(2)(b) Reclamation Plan - Cost Estimate The reclamation costs section of the permit application indicates that 1987 will be the "worst case" year in terms of estimating the total cost of reclaiming the Seneca II W mine during the initial 1985 - 1990 permit term. This is based on an assumption that four spoil ridges behind the active pit will require regrading. It is unclear, however, as to whether the material volumes provided in support of this assumption in Table 13-1 include the minimum of two overburden ridges remaining behind the 1986 left open pit, the overburden remaining from the initial box cut, the overburden remaining from the second box cut opened in early 1987, and the maximum of four overburden ridges situated immediately behind the active pit as mining operations progress through 1987. In order for the Division to verify the worst case assumption, the applicant will need to provide more detailed information on the development of active pits and the movement and stockpiling of overburden during the proposed permit term. Additionally, the applicant should review the estimated push and haul distances utilized in costing out the regrading work on page 13-66 of the application. It appears that certain portions of the pit left open at the end of 1986 will require longer scraper haul and/or dozer push distances. Page 13-69 of the Reclamation Plan portion of the permit application details the estimated cast of removing surface material from haul roads. It is stated that "After 3 feet of material has been removed, scrapers will haul an additional foot of material to an open pit." This section of the reclamation cost estimate must be amended to cover the cost of removing the upper three feet of material. It appears that the cost figure provided only covers the cost of using scrapers to remove the lower one foot of material.