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__ page c Jim Herron During my completeness review, I have preliminarily identified a number of significant adequacy concerns: Rule 2.05.3(3)(c) ~ 4.03 - Roads (Stability Aspects) The proposed steep cross slope haul and light use road system contains a number of significant cut slopes and fill embankments. These slopes and fills will require appropriate stability analyses. Cross-sectioning should be prepared for the critical cut, fill and composite sections. Rule 2.05.3(6) - Overburden Handling The applicant should provide supporting data for the 15.3 swell factor presented within the application, which the applicant discerned at the nearby Seneca II mine and believes to be representative of the Seneca II-West mine. The applicant should analyze the bulking of the entire range of overburden sections to be encountered, in addition to the average section analyzed within the application as originally submitted. Rule 2.05.3(6)(a) & 4.08 - Blasting The applicant should clearly state whether or not any potentially affected structures exist within 0.5 miles of the permit boundaries. If such structures exist, they should be clearly identified on an appropriate map. Rule 2.05.4(2)(c) & 4.14 - Reclamation Plan - Backfillino & Gradin If the box cut spoil is proven to be acceptable (not necessary to achieve approximate original contour within the mined area), the applicant will have to demonstrate that the proposed placement of the material will be stable, in compliance with Rule 4.14.2(1)(b). In addition, the applicant will have to demonstrate that the critical road cut slopes and fill embankments can be backfilled in conformance with the same stability requirements. Further, the cross-sections presented Topography Map do not appear to agree with overburden bulking. Significant additional support the proposed Postmining Topography. within EXHIBIT 12 and the Postmining the projection of general negative detail will be required to cc: Brian Munson