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<br />It's appazent from Maps 2.05.3-1 and 2.05.3-2 that the access road is planned through the <br />P1/P2 fill. Please address. <br />Please remove plans for proposed "culverted fords" of the perennial stretches of the <br />Lorencito Canyon stream. Fords of perennial streams by access roads is regulatorily <br />prohibited (Section 4.03.2(2)(c)). <br />Rule 4.05 Hydrologic Balance <br />Under this section, all responses were found adequate except as listed below. <br />146. This response is inadequate. A few years of monitoring shotcrete ditches would not <br />provide useful information on the long-term integrity of shotcrete ditches. As the use of <br />shotcrete is proposed for ditches designed to safely handle the 100-year event, it is <br />reasonable that the Division is presented evidence that shotcrete lining can withstand the <br />forces of nature for at least 100 years. Furthermore, the use of riprap and\or vegetation <br />lends itself to a channel which over time will likely become more stable through <br />vegetation invasion, including shrubs and trees, and minor, natural channel downcutting <br />and stabilization. shotcrete or a similar "impermeable" channel lining would prevent <br />vegetation establishment and becomes less stable over time. Therefore, this response is <br />inadequate at this time. <br />147. The Division understands, at this time, a response is forthcoming. Therefore, this <br />response is inadequate. <br />148. Pond information was modified across the board on EX 15-14 (which was originally EX <br />15-11). This information was reviewed in it's entirety along with Exhibit IS design <br />information. The following problems were noted: <br />RI Portal <br />a) The Division notes that no drainage plan for the R2 portal have been submitted. <br />Our understanding is that this portal is planned for the second five year term. <br />b) On Figure EX 15-3A, are ditches D7B\D7C and CDW directly adjacent? If so, <br />please delineate of the figure. <br />c) CWD ditches should be labeled on the figure using the same terminology as Table <br />15-3. <br />Coal loadout <br />d) The coal loadout pond is generally square. A rectangular pond, with the inlet as <br />far away from the outlet is recommended and is the assumption that SEDCAD+ <br />is using in the modelling. The Division recommends a 2:1 length/width ratio for <br />