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:: • s <br />operator must demonstrate that retention of the road is compatible with the <br />approved postmining land use, that the road complies with all applicable <br />performance standards, and that the landowner requests the road be retained. <br />I will address these requirements in reverse order. <br />Landowner Concurrence: <br />Since C-YVCC owns the majority of the surface under consideration, it is <br />logical to assume that C-YVCC will be able to demonstrate that it concurs with <br />its own desires to retain the roads in question. <br />Compliance with Performance Standards <br />The existing roads have been found by the Division to be in compliance with <br />the performance standards governing operation of amine. In the recent past, <br />culvert clogging and erosional problems have been cited through the <br />enforcement process for the large road embankment located near the <br />northwestern boiundary of the Eckman Park mine. Performance standards deal <br />with the operational requirements of the road system. As an example, culverts <br />are designed for normal project life, as projected in the mining plan. The <br />operators rationale in the technical revision application assumes infinite <br />project life for the CMP culverts. Realistically, when their operational life <br />expectancy is exceeded those culverts will collapse, leaving the surface <br />drainage system blocked in numerous locations. <br />The normal road embankment is configured to direct drainage accumulated on its <br />top surface to outfall structures. The proposed amendment to narrow the road <br />surface and plant the remainder of the embankment top surface will render the <br />planted areas uncontrolled, allowing drainage to break over the side slopes <br />resulting in erosion and attendant sediment generation problems. <br />Land Use Compatibility <br />Herein lies my major objection to the proposed retention of the operational <br />road embankments on the reclaimed landscape. To be compatible with the <br />ranching postanining land use, the road system must be appropriate for that <br />land use. This should not be confused with the road system being capable of <br />accommodating the proposed postmining land use. A rancher can certainly drive <br />his cattle truck along a 50 foot wide roadway. However, he only requires a 15 <br />- 20 foot wide road on a 20 - 25 wide embankment. Faced with the task of <br />constructing a road, that same rancher would construct only as large a road as <br />he needed. An oversized road will cost more than necessary to construct <br />initially and to maintain. Even if the rancher, as projected by the operator, <br />performed annual maintenance and cleaning, these operations will cost <br />proportionately more for an oversized road. A rancher, as any other prudent <br />businessman, must avoid over expenditure. <br />These principles are evident in any non-mine-related ranch road. As an <br />example, if a drainage requires a 24 inch culvert to pass the normal high <br />flow, a rancher will probably install several 12 inch culverts or a low water <br />crossing, instead. 12 inch culverts require a much smaller excavation to <br />install. They can be buried with less cover and support heavier live loads. <br />The embankment needed to conceal the 12 inch culverts requires a fraction of <br />the earth work needed to accommodate the 24 inch culvert. The smaller <br />embankment will have less toe to toe width and require shorter culverts. <br />