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Ms. Erica Crosby September 4, 1996 Page 2 not see any problems with our plans, and stated that Seneca would have to acquire an oversize permit to walk the dragline on both RCR 27A and RCR 27. He said that we should submit this plan a month or so before the actual move so that all necessary items could be addressed. On October 23, 1995 at 10:00 am, Mr. Scott Williams, then General Manager, and Mr. Chuck McCulloh, Senior Engineer - Operations met with Mr. Larry Routten and Ms. Susan Burqmaier, Division staff, to discuss these same deadhead plans. i gave Chuck a list of additional questions to ask so that Seneca would have a clear idea of what we would be required to provide. One question specifically asked if we would need to revise the Seneca II mine Permit C-80- 005, to include the mine entrance road and any related disturbance associated with the move. Mr. Routten and Ms. Burqmaier stated that this road need not be permitted. The main items of concern were: if any baseline soils work had been done along the Yoast corridor where disturbance would take place, sediment control during and after the move, the stability of the drainage after, and the appropriate correspondence from the landowners and Routt County. During the time we have discussed this project, the Division has been revising their regulations concerning public roads. Seneca has hauled coal on RCR 27A and RCR 27 at the Seneca II mine for the last twenty-eight years. These county roads have never been permitted and we have always maintained them. This portion of the rule changes was eventually taken out of the revised rules process. Since that time, I have repeatedly asked both Ms. Susan Burqmaier and Ms. Janet Binns, inspector for the Seneca II mine, in phone conversations and during monthly inspections if we had to permit these county roads and the work associated with the deadhead of the dragline. On every occasion, I was told that permitting these county roads was not necessary. Seneca Coal Company submitted to you, Technical Revision No. 3 to the Yoast permit, 650 Dragline Deadhead Route - Incidental Permit Boundary Change, on July 29, 1996. Since that time you and I have talked on the telephone and had discussions at the minesite addressing all the concerns the Division had with respect to this revision. At no time during this review process, did the Division discuss why no materials were submitted for the widening of RCR 27A. Both you and Mr. Larry Routten inspected the mine on August 19, 1996. Accompanying both of you were, myself, Chuck, Mr. Brad Brown, General Manager, and Mr. Roy Karo, Reclamation Foreman. We specifically discussed the deadhead route and revision work. The road slope along RCR 27A was spray painted showing the existing road width to determine how much material needed to be excavated along RCR 27A. We stated that we were having a meeting on August 22, 1996, with Mr. Paul Draper, Director, Routt County Road-Bridge-