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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection, The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />The extent ojroad reclamation is somewhat variable, and it would appear tha[ additional <br />reclamation will be required jot certain road segments. The operator may need to do <br />further records research and consul! with BLM (surface landowner) to resolve certain <br />questions regarding road reclamation requirements. <br />Questions regarding the adequacy of road reclamation were raised with respect to the following <br />locations: <br />PCC-04 and OS access road road stabilized by vegetation but not completely obliterated). <br />PCC-10 access road not fully obliterated fmm end ofpernanent road to junction of PCC-10 <br />reclaimed road with PCC-9 reclaimed road. <br />PCC-Ol road not completely obliterated. <br />PCC-02 access road initial segment not completely obliterated. <br />There were no erosional problems noted with regard to the road segments mentioned, but grading had not <br />completely eliminated the roads in some locations. The operator was directed to contact BLM, the surface <br />land management agency, regarding their opinion on the need for further reclamation work. <br />The January 7, 1998 letter from Catherine Robertson of BLM Grand Junction Resource Area to <br />Larry Reschke (then with Powderhom Coal Company), documents an inspection conducted by <br />Bruce Fowler and Dave Trappett of BLM, on September 3, 1997. In the letter, Ms. Robertson <br />states that "the inspection included three access roads to drill holes identified as PCC-OI through <br />PCC-10..." Specific comments regardingBLM's desire for further reclamation work on the road <br />segments in question include the following: <br />This access (to PCC-IOJ has been identified for use in the Grand Mesa Slopes recreation <br />plan and therefore we do not want arty additional reclamation completed on this access. <br />The reclamation requirements for (tfre access road to PCC-4 and S] was to install <br />wa[erbars and to seed it. This work has been completed. Vegetation has been established <br />and additional reclamation would be counter productive as it would cause additional <br />unnecessary erosion. BLM does not want arty additional disturbance to occur on this <br />reclaimed area. <br />This road (!he access to PCC-01 through 03) has been reclaimed to the requirements ojthe <br />approved plan. Specifically, BLM requested that the portion ojthe access road south and west of <br />the South Portals [actually, the 2-West Pottals] be left in place and not recontoured...This was <br />requested to facilitate livestock management. Therefore, the BLM does not want arty additional <br />reclamation completed on this access road <br />In summary, the BLM in then letter indicated their satisfaction with each of the road segments identified by <br />DMG as possibly needing additional reclamation work. BLM specifically requested that no further <br />reclamation work be performed on these roads, and [hey identified no additional concerns regarding <br />reclamation of the roads or drill pads. This determination was re-affirrrred by DaveTrappett and Bruce <br />Fowler of BLM, during the bond release inspection on August 14, 2001. Based on the 1997 inspections <br />l0 <br />