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outlet protection measures should be described. 6. A written request to retain for postmine use (with culverts removed) the portion of the access road depicted on Figure 3.1-10, which is on BLM surface, will need to be obtained from BLM prior to revision approval. 7. Slope stability analyses performed on the five representative cross sections on the haul road and portal bench utilized material strength parameters which were assigned to the two soil materials encountered on the haul road slopes, as well as to the general backfill to be used in reclaiming the mine portal bench. No laboratory data or other source was provided for the development of these material strength parameters (cohesion, angle of internal friction, and density). In addition, the application indicates that coal material from the Loma loadout would be used to partially backfill the portal bench. However, no indication of this intention is evident on the analytical cross sections, and no material properties are provided for this material. Material strength parameters used in the analyses need to be justified, and the portal bench analyses need to be amended to reflect the presence of the coal material from the Loma loadout. 8. The mine site reclamation plan text should be amended to specify that the coal material imported to the site, and any exposed coal seams will be covered with at least four feet of non toxic, non combustible material. 9. Existing mining disturbance limits and limits of disturbance associated with the mine site reclamation plan should be delineated on Exhibits 3.1-4 and 3.1-7, respectively. 10. The Division currently holds a $324,408.75 reclamation bond. As a part of this revision, the operator is requesting that the Division grant a bond reduction based on the fact that certain permitted disturbances including haul road upgrading, portal bench expansion, and refuse area development, have not been initiated. The Division is amenable to the bond reduction for the reasons stated, however the revision approval would need to be conditioned as explained in the cover letter. The operator has estimated that the bond liability should be reduced to $138,000.00, whereas the Division has evaluated the proposed reclamation plan for the existing disturbance, and estimated a reclamation cost of $188,506.00. A copy of the Division's estimate is enclosed. The primary differences between the operator estimate and the Division estimate which will need to be resolved are: Task 10; Grand Valley estimated a cost to backfill the four portals on site, excluding the cost of portal seals, because the seals have already been installed. Rule 3.02.2(5) allows a permittee to request bond reduction based on demonstration