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TR-37, PAP Update and <br />Permanent Facilities Request <br />Page 2- <br />b) With regard to providing a commitment for every minute detail, SCC believes the submittal of the State <br />Engineers approval is just an integral part of the process and that a narrative commitment is overkill and is <br />not specifically required by law to be included in the PAP. <br />23. In our original comment to SCC, we stated that under the capacity discussion for Stockpond ST-1 permanent demonstration, <br />SCC indicates that "since the capacity is under the 2 ac. ft. limit, the State Engineer's office does not need to review the <br />permanency request .................. <br />.............Please pmvide the Division with documentation thatpr+opernotifrcation has been <br />made and revise the Stockpond ST-I Permanent Pond Demonstration accordingly to reflect this, <br />orprovide a commitment to provide such documentation within an appropriate revision <br />application, pn'or to submittal ofa Phase I bond release application for Stockpond ST-L <br />Response: Attached is a copy of the form "Application for Livestock Water Tank" for ST-1 that was <br />submitted to the Division of Water Resources in the Steamboat Springs office. <br />25 Requested clarifications regarding permanent mad requests were provided. Operator responses indicate that SCC has been in <br />contact with Yampa Valley Electric Association (YVEA) and Public Service Company of Colorado (PSCO), and has <br />requested necessary letters documenting requests for retention of the power line extending from the Rockcastle road up through <br />the permit area to the substation, however such documentation has not beenyet been provided to SCC. <br />Please provide amended language in Attachment 20-1 that commits SCC to provide (within an <br />appropriate revision application) documentation from YVEA and PSCO regarding their request <br />for retention of the power line and any associated electrical structures, prior to submittal ofPhase <br />I bond release for the structures. <br />Note that, since the necessary documentation has notyet been pmvided, the pending SL-2 phase 1 bond release application <br />will need to be amended to exclude the YVEA power line from the area requested for release. <br />Response: SCC believes that rather than amending SL-2 the Division can just remove the acreage during the <br />preparation of the Findings Document (as has been done during other bond release inspections). With this <br />approach, there would not need to be multiple revisions to the permit or bond release application document. <br />Then once SCC receives the final decisions from the appropriate entities, we will provide the documentation <br />for approval. <br />28. In the original review letter, the Division requested an update regarding the status of retention of a light use road segment <br />connecting proposed Light Use Roads 3A and 3B. The operator's response was that appropriate sections of the permit will <br />be updated when changeslagreements /with BLMJ are finalised. Although the `missing" mad segment is not depicted on <br />the Postmining Topographic Map Exhibit 20-2, the topographic mnulations in the YPM-8 watershed and the alignment of <br />the YPM-8 drainage channel (with the sharp right angle turn at the water bar location) reflect retention of the road. <br />Ifit is SCC's intent that one or more of the existing roads within the reclaimed area corridor <br />between LU-3A and LU-3B are to be retained as permanent, please indicate the proposed final <br />road segment configurations on Map Exhibit 20-2, and include a narrative commitment within <br />Attachment 20-1, to provide (within an appropriate revision application) necessary landowner <br />inquest for retention of the mad segments for the postrnining land use, prior to submittal of a <br />Seneca Coal Company a P.O. Box 670 a Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222