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"Relevant Showing" Adequacy Review 1. In order to accomodate the recent rule changes, it would appear that a technical revision will be necessary to revise or clarify various permit application text sections, including IV.D.2, IV.G, and IV.H.3. Throughout the text, outdated federal regulatory citations and terminology are used, and the text should be revised to reference appropriate state rule citations and terminology. For example, the terms "haul road", "access road", and "light use road!'_ should be used rather than "Class t'~; "Class II", and "light duty road". The application text needs to specifically state which roads are "haul roads", which are "access roads" and which are "light use roads", with reference to design, construction, maintenance, and reclamation requirements for each category of road. The various. pre-existing and wnPP~~tt ~~ads_used to access de-gas sites, drill sites, and de-wateigili'~ "Si`~es are...ua#._.~uzrently listed in the "Roads" section of the permit application text, and the narrative needs to be appropriately amended. The text in the permit application which addresses County Road 65 should clarify that it is a public road for which WFU has no continu.iAg maintenance or reclamati25ri responsibilYty"undey the permit. 2. Page 2 of the letter notes that the permit contains an exception to the Rule, in that a portion of the refuse haul road will be "only partially reclaimed so as to maintain the previously established access for the local ranchers." Rule 4.03.1(f)(ii) requires removal/reclamation of all haul roads unless a written request for retention of the road or parts of the road is submitted to the Division from the landowner. The application in Section IV.D.2 states that, "when mine operations cease, WFU will request both the BLM and Rio Blanco County to submit a letter of request for retention of the road." It is not clear why Rio Blanco County would be involved, unless the road would be designated as a county road upon completion of reclamation, but the written request from the landowner (assumably BLM) needs to be acquired and included in the permit. The commitment to obtain the written request at some point in the future does not satisfy the requirement of 4.03.1(f)(ii). 3. The third paragraph on page 2 of the letter cites Rule 4.03.1(d)(ii). The correct Citation is 4.03.1(1)(d)(ii), and the letter should be appropriately amended. Page 3 of the letter also contains an apparently erroneous citation; the reference to Rule 4.03.1(f)(ii) should be 4.03.2(1)(f)(ii).