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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 15 <br />presents adequate information to demonstrate that the proposed permit area does not contain <br />Prime Farmland. <br />Pursuant to Rule 2.04.12(3), the Division makes a negative determination regarding the presence <br />of prime farmland within the proposed Red Cliff permit area, based on the fact that the land has <br />not been historically used as cropland [2.04.12(2)(a)], and further based on a letter from the <br />NRCS included in Exhibit 14, documenting that there are no prime farmland soil map units <br />within the proposed permit area [2.04.12(2)(f)]. <br />Rule 2.05.3(2) Operation Description <br />38. There is an error at the end of the "Benches" sub-section on page 2.05-7. Reference to <br />"raw coal from the mine" should be "clean coal from the coal preparation plant". Please <br />amend the narrative as appropriate. <br />Rule 2.05.3(3) Operation Plan-Roads <br />39. On page 2.05-22, narrative indicates that all topsoil will be removed from areas to be <br />disturbed by road construction. Steep slope and canyon areas traversed by the upper <br />segment of Haul Road #1 (as well as Dry Office and Portal Facility areas) are located <br />within the area delineated as Soil Map Unit F, Rock Outcrop, in Exhibit 7, Soils Baseline <br />Survey. According to the survey report, the Rock Outcrop unit is characterized by steep <br />slopes, with "barren escarpments, ridge caps, and rocky points of sandstone, shale, <br />limestone, or siltstone". On these sites, no material classified as topsoil would be <br />available to salvage. <br />However, the report notes that "Torriorthent" soils from 4 to 13 inches in depth are <br />present within the unit, comprising less than 15% of the area. Presumably, these soils <br />occur within a narrow band along the canyon bottoms. The survey report states on page <br />20, that it may be possible to salvage small inclusion areas of the "Torriorthents" soil that <br />occur within the disturbance area. <br />Please clarify, within the appropriate section(s) of the application, how any such small <br />inclusions of the "Torriorthents" soil within Map Unit F will be identified, delineated and <br />salvaged, in association with haul road, office, and portal facility construction activities. <br />40. The "Haul Road Reclamation" narrative on page 2.05-24 states that the section of Haul <br />Road 1 from State Highway 139 to the preparation plant area will not be totally <br />reclaimed, but will be narrowed to a travel width of 14 to 16 feet, with culverts removed. <br />Rule 4.03.1(f)(7)(ii) requires that all haul roads are to be removed and fully reclaimed, <br />unless "the landowner requests to the Division in writing, that the road or certain parts <br />thereof are to be left open for further use". The written landowner request has not been <br />provided.