Laserfiche WebLink
-8- <br />A geotechnical investigation done by Robert Thompson in 1977 indicated that <br />areas of instability existed along the road corridor and suggested measures to <br />mitigate these stability problems. Review of this report and field <br />investigation by the Division indicate that these areas of instability are <br />still unstable, and that the recommendations of the 1977 report have not been <br />followed. A memorandum from the Division staff geotechnical expert concerning <br />the haul road is attached at the end of this report (Addendum A). The <br />Division feels that the road will continue to experience geotechnical <br />instability in its present configuration, and therefore does not meet the <br />requirements of Rules 4.03.2(3)(c)(i) and 4.03.2(3)(d)(viii). <br />Significant erosion problems exist at the outlet of several road culverts, <br />sediment traps, and rolling dips. Five violations have been written by the <br />Division for erosion problems associated with the road, with one of these <br />being issued in the decommission phase. Based on the current erosion problems <br />and off-site impact, the road does not meet the requirements of Rule <br />3.03.1(3)(b), 4.03.2(1)(b), and 4.03.2(4)(a)(iv). Further, it is possible <br />that the integrity of the road itself may ultimately be compromised as a <br />result of this erosion. The erosion problems also indicate that the outslope <br />vegetation does not meet the criteria of 4.15.10(2). The Division feels that <br />this is further evidence that the road is not functioning properly as <br />designed. <br />Within the haul road certification submitted by the operator, it is stated <br />that "several areas (of the haul road) appear to be unstable as a result of <br />the CMLRD decision to require outslope drainage control methods". No specific <br />method of controlling water from the haul road was required by the Division. <br />The applicant is required to submit a plan for Division review to determine <br />whether the plan will ensure compliance with the law. The current haul road <br />decommission plan was arrived at through discussion between the Division and <br />the operator, and review by the Division which found that the plan would <br />reasonably ensure that runoff and erosion would be controlled. However, the <br />Division recognized the difficulty of achieving the objective of the plan, and <br />as reflected in Stipulation No. 1, conditioned the approval to require <br />specific performance, monitoring, and maintenance of the haul road structures. <br />Post-Mining Land Use (PMLU) - The Division is in receipt of twenty-two <br />letters an numerous p one ca s rom the landowner which voice <br />dissatisfaction with the road pursuant to the post-mining land use. The <br />landowner states that due to problems with snow plowing, the road surface, the <br />rolling dips, and off-site erosion, the intended PMLU cannot be realized. The <br />Division feels that the landowner concerns are essential to the PMLU <br />determination, since in accordance with Rule 2.05(1)(a)(iiv) the approval to <br />leave structures for the PMLU must be consistent with surface owner plans and <br />programs. <br />