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The Division issued a preliminary adequacy review letter on November 10, 2003. The letter ident~ed a number of deficiencies and requested amendments to the application. Amendments were requested with respect to ownership and control information, -map certifications, soil resource information tables, impoundment designs and various aspects of the proposed operations and reclamation plan changes. Following numerous extension requests that were granted by the Division, SCC submitted an initial adequacy response package with proposed amendments on May 14, 2004. SCC had waived their right to a proposed decision within 180 days of completeness determination in a letter of March 17, 2004. The Division completed an independent worst case disturbance assessment and reclamation cost estimate, which was forwazded to SCC on June 30, 2004. The Division forwarded a 2°" adequacy review letter to SCC on July 7, 2004. Remaining issues of concern included map certifications, soils resource table updates, reclamation scheduling details, Pond 017 stability analysis, stock tank impoundment designs and certifications, and worst case bonding assumptions. The Division also requested certain updates to Exhibit 20-1A (Year 2001-2005 Disturbance Map II-W South). SCC submitted an amendment package in response to the 2v° adequacy letter on September 1, 2004 (received by the Division on September 7, 2004). A final adequacy review letter was forwarded to SCC on September 17, 2004. Several previously identified adequacy concerns that had not been fully resolved were ident~ed in the letter, and proposed stipulations were set forth in the letter to address these concerns. These stipulations (34 through 38) have been attached to the PR-3 Proposed Decision. In a letter of September 27, 2004, the Division noted that a bond rider submitted by SCC had been approved. The rider brought the actual bond amount held to $9,707,373.00, which exactly corresponds to the worst case reclamation cost calculated by the Division, in conjunction with PR-4. The Division queried the Applicant Violator System (AVS) on several occasions during the PR-4 review, and there were no violations listed; recommendation based on the AVS checks was "Issue". Description of the Environment The Seneca II-W Mine is located in northwest Colorado approximately 7 miles south of Hayden in Routt County. The Seneca II-W Mine lies 7 miles west of the Seneca II Mine, Permit No. C-80-005 and 3.5 miles west of the Yoast Mine, Permit No. C-94-082. The mining area can be found on the Hayden, Hayden Gulch, Mount Harris and Dunkley Quadrangles 7.5 Minute Series Maps. The coal from Seneca II-W is hauled over county and private roadways by private hauler to the Hayden Station Power Plant operated by Public Service of Colorado. Haulage distance is Seneca II-W Findings Document 7 November 17, 2004 Permit Revision No. 4