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13. Revised page 134 includes a description of situations which would result in the <br />creation of four or more spoil ridges behind active mining pits. While we agree with the <br />justifications presented, we believe each of these situations should be evaluated and <br />approved by the Division on an individual basis. Please include a commitment to notify <br />and receive approval from the Division for delays in contemporaneous rough grading. <br />14. The Reclamation Schedule on page 13-44 lists the time period for each reclamation <br />activity performed. The time period for backfilling, grading, and drainage control <br />stabilization appears to contain a typographical error. The time period listed is <br />"minimum 4 spoil piles..:'. It would appear that the intended word was a maximum of <br />4 spoil piles. <br />15. As previously stated, the Reclamation Schedule should include a specific time period <br />during which topsoil replacement will be completed. <br />16. Revised page 13-45, Reclamation Schedule, should include establishment of adequate <br />topsoil replacement depth in the time period column for Phase II bond release request. <br />17. Revised page 13-49 states that all structures will be removed assuming PWCC does not <br />receive any bonafide requests from the postmine landowner to the contrary. Please <br />include a statement that any such request is also subject to Division approval. <br />18. Revised page 13-49, under the Powerlines heading, indicates that several poles may be <br />left as raptor perches in interior reclaimed areas. PWCC should either remove the <br />statement or include documentation of approval for pole retention by the United States <br />Fish and Wildlife Service, Colorado Division of Wildlife, the landowner, and our <br />Division. <br />19. Revised page 13-49 states that perimeter fences will be removed where not necessary <br />to meet final fence configuration for postmine land use management. Please specify <br />which segments of the perimeter fence will be removed. <br />20. Revised page 12-50 states that all remaining access roads will be reclaimed assuming no <br />bonafide requests area received to leave additional roads. Please include a statement <br />that no roads will be left without also receiving Division approval. <br />21. Revised page 13-52 explains that the reclamation cost estimate was based on a worst <br />case of four standing spoils behind the open pit. PWCC says that "this is a very <br />conservative estimate because, in most cases, reclamation grading is current to within <br />two spoil piles:' Page 13-44 lists numerous scenarios which would create more than four <br />spoil ridges. In the upcoming five year permit term, does PWCC anticipate creation of <br />more that four spoil ridges at any point in time? If so, PWCC should revise its <br />assessment of the maximum reclamation requirement and associated cost estimate <br />accordingly. <br />22. Revised page 13-53 includes an estimate that redistributed topsoil will be bulked by a <br />factor of 1.4375 from the stockpile to final redistribution. We believe this factor may <br />ary en t 3 u y 13, 1 9 <br />