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Memo to Mike Boulay MCC PR-07 Third Round page 2 operational and reclaimed configurations for the SGFA by submitting a proposed "Construction Approach and Construction Monitoring Program for Potentially Unstable Slopes". Included within the approach proposal documentation is the results of back calculated (sensitivity-style) stability analyses of areas known to have previously evidenced slope instability. These analyses were prepared in response to Division request. MCC proposal presents an "observational" approach to control destabilization of the SGFA. Four specific components are discussed: 1) Collection of geotechnical information in specific locations, and preparation of additional slope stability analyses prior to construction in these areas. In connection with this component, MCC clarifies the critical-path construction priorities within the SGFA. Areas of particular adequacy concern to the Division, the widening of the Sylvester Gulch Lower Access Road and the completion of the upper light use road from Pad #2 to the Water Tank are not proposed for immediate construction. MCC proposes to collect additional observational and sampling data prior to completion of these activities. MCC's discussion does not specifically address the submittal of any additional information concerning these data collection and design activities. I believe it would be appropriate for the Division to require that MCC specifically update the Division regarding these activities. In the case of the upper portion of the light use road to the Water Tank MCC should simply be required to provide the Division with the results of the additional sample collection, laboratory analyses, stability analyses, and redesign if appropriate, prior to commencement of any construction above Pad #2 for the powerline. In the case of the lower portion of the Sylvester Gulch Access Road it is difficult to specify a critical point in progress for a specific submittal. Rather, MCC should commit to specifically addressing this concern in the weekly monitoring updates. 2) Detailed field monitoring including frequent on-site observations by environmental, engineering and geotechnical professionals. As discussed above, MCC has committed to the installation of monitoring stations (flagging, lath site lines, and reflector stations), and the completion of extensive monitoring throughout and following the SGFA construction activities. The plan appears comprehensive, in my opinion. MCC is somewhat passive in its proposed provision of the monitoring results, however. MCC states, "Weekly summary reports will be made available at the Division request." I believe it would be appropriate for MCC to commit