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5. Three (3) roads will remain at the time of mine closure: Skyline Drive, <br />West Ridge Road, and the existing North access road. It is necessary to <br />retain Skyline Drive since it provides access to the Routt County dump <br />and to the D&RGW communication facilities. The North access and <br />West Ridge Roads are necessary to provide all-weather access from the <br />Routt County road system to land within the permit boundary. <br />6. Along selected segments of the haul road in the Moffat Area spacing of <br />culverts was not in compliance with Rule 4.03.1(4)(e)(vi). A variance <br />has been granted based on the following findings: <br />A. Culverts were located in areas of preferred or existing drainage, <br />B. Stable road embankments were designed, <br />C. Road grades were not excessive, and <br />D. All haul roads are contained within a sediment control system. <br />The operation is in compliance with the requirements of this section. <br />7. The only special category of mining proposed by P&M is for operations on <br />steep slopes. An access road to the Edna Mine is known as the <br />"Goat Trail" (Volume 8, Exhibit 3.5-1 and Road Profile 1-1', <br />Exhibit 3.5-13). This road was constructed in 1953 prior to any road <br />design standards or reclamation requirements. The hillside upon which <br />the "Goat Trail" is established varies in slope from 30 to 70 percent, <br />with an average road grade of 6.6 percent overall and maximum grade of <br />10 percent in two (2) locations. P&M has received a variance from <br />meeting AOC during reclamation of this road because the regrading <br />activities would create additional environmental damage and result in <br />instability on this steep slope. <br />8. The only applicable miscellaneous compliance rule pertains to surface <br />coal mining activities within 500 feet, measured horizontally, of <br />abandoned underground mines. The Division approved this practice because <br />of the improved resource recovery from mining the Lennox, Wadge, Lower <br />Wadge, and Rider Wadge seams where available in West Ridge, Center Ridge <br />and the Moffat Areas. <br />Approval by the Mine Safety and Health Administration (MSHA) to mine <br />within 500 feet, measured horizontally, was received on October 28, 1981. <br />-7- <br />