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SENECA II-W TR-68 PAR COMMENTS <br />1. "Shop and Storage Area" was deleted from amended Attachment 20-2 Table of <br />Contents, and from the listing of Permanent Features/Structures on page 20-2.1. The <br />corresponding section was also deleted from the body of the Attachment narrative on <br />page 20-2.3. However, there is reference to postmining retention of the shop facility <br />under the Access Road "A" narrative, "Powerline and Substation" narrative, and the Light <br />Use Road 2 (LU-2) narrative. The Shop and Storage Area is also listed as a requested <br />permanent feature in the SCC landowner letter in Appendix 20-2.1, and is depicted on <br />Exhibit 20-2 "Postmining Topography and Drainage Map". We note that although the <br />Table of Contents page and page 20-2.1 of the submittal are marked as having <br />originated with TR-62 in 01/09, they differ from the currently approved versions of these <br />pages, which are also marked "01/09" and "TR-62". It would appear to be possible that <br />a preliminary version of the TR-62 pages was inadvertently updated for the TR-68 <br />submittal, rather than the final approved version of TR-68. <br />Please clarify whether it is SCC's intent to retain the Shop and Storage Area as a <br />permanent feature. If the shop area will not be retained, it is not clear whether there <br />would be a reason to retain the Shop Well, LU-2, or the powerline from the Substation to <br />the shop (and associated segment of LU-1). Please address these questions and <br />revise the appropriate sections of Attachment 20-2 text, Appendix 20-2.1, and <br />Exhibit 20-2 as appropriate to be internally consistent. <br />2. The first sentence of the third paragraph on page 20-2.1 (Landowner Access Road <br />Documentation) is an incomplete sentence fragment. The corresponding sentence on <br />the currently approved version of the page is a complete sentence, which would seem to <br />point to the possibility noted in Item 1, that a preliminary version of page 20-2.1 was <br />inadvertently updated for TR-68, rather than the approved version. <br />Please correct the sentence as appropriate. <br />3. For clarification, it would be helpful to note within the narrative for County Road 53C, that <br />the road includes both the MEHR road, which would be reduced for the postmining land <br />use, and the Oil Well Access Road. Please make this narrative clarification, and <br />include the approximate length of both the MEHR section and the Oil Well Access <br />section. <br />4. The amended narrative for LU-1 on page 20-2.2 incorporates a segment of road that <br />extends to the west of the Substation along the powerline for approximately 3980'. A <br />significant length of the powerline segment (approximately 2,100') has a grade of 15.2%, <br />with shorter segments ranging from 0% to 11.9% (LU-1 Profile Drawing on new Exhibit <br />13-28). The length of the relatively steep gradient sections of the powerline segment <br />results in over-all average gradient for LU-1 which exceeds 10%. <br />With the exception of pre-existing roads, Rule 4.03.3(3)(a) specifies that overall grade <br />for a light use road shall not be steeper than 10%. Narrative indicates that the steepest <br />segment of the road (and possibly the entire power line segment, though this is not <br />entirely clear) "existed prior to powerline construction". This would seem to imply that