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TR-61 AND MIDTERM RESPONSE REVIEW <br />Review Comments Pertinent to TR-61 PAR Letter (9/24/08) <br />The Division questioned whether revised Table 19-1 included Tie-Across Haul <br />Road (TAHR) acreage, and also requested clarification in Tab 19 text to address <br />the backfilling and grading schedule for the TAHR. <br />Table 19-1 acreages were properly revised. SCC proposes retention of TAHR <br />until 2030, "due in part to potential future mining in western Routt County that <br />could require the use of this road". <br />With respect to the TAHR reclamation schedule, the Division is aware that the <br />road may have future mining related use associated with coal reserves further to <br />the west, and we believe it is prudent to allow for the road to remain in place as <br />long as there is a substantial likelihood of such use in the near future. For the <br />present, the Division will accept the 2030 date for reclamation of the road, and the <br />issue will be reviewed during future permit renewals to assess whether the <br />schedule remains appropriate, and whether retention of the road within the II-W <br />permit is appropriate versus transfer to a different permit. Item Resolved. <br />2. The Division noted an apparently erroneous alignment depicted for the light use <br />road across the upper portion of the reclaimed 016 watershed on approved Exhibit <br />20-2 (as compared to amended Exhibit 19-1 and aerial photos), and requested that <br />Exhibit 20-2 be amended to depict the actual alignment. <br />An amended Exhibit 20-2 was provided, depicting the correct alignment of the <br />light use road. There were a number of additional changes to Exhibit 20-2, which <br />were not requested, including depiction of additional proposed permanent <br />facilities (e.g. the mine shop, storage area, and adjacent well house, additional <br />culverts, electrical facilities, and fencing). Also, the watershed boundary layer <br />was removed from the amended map and all of the cross section locations were <br />deleted. The watershed boundaries and cross section locations should not <br />have been deleted and will need to be restored. Additionally, due to logistics <br />and given that most of the map changes relate to retention of proposed <br />permanent facilities, we make the following request: <br />Please withdraw the revised PMT map from TR-61 and address all PMT <br />changes and Permanent Feature changes in a future, separate technical <br />revision application. <br />3. The Division noted apparent discrepancies regarding shop area and Pond 006 <br />grading deadlines and requested clarification. <br />2