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TR-68, Permanent Light Use Road Documentation <br />Response to Comments <br />page 2 <br />Please correct the sentence as appropriate. <br />Response: The sentence has been corrected in the attached Attachment 20-2. <br />3. For clarification, it would be belpful to note within the narrative for County Road 53C, that the road includes both the <br />MEHR mad, whicb would be reduced for Abe postmining land use, and the Oil Well Access Road Please make <br />Ibis narrative clarification, and include the approximate length ofboth the MEHR section <br />and the Oil Dell Access section. <br />Response: The narrative in Attachment 20-2 has been revised. <br />4. The amended narrative for LU-1 on page 20-2.2 incorporates a segment of road that extends to the west of the <br />Substation along the Powerline for appmximately 3980'. A significant length of the powerline segment (app%ximately <br />2,100) has a grade of 15.2%, with shorter segments ranging from 0% to 11.9% (LU-1 Profile Drawing on new <br />Exhibit 13-28). The length of the nlatit+ely steep gradient sections of the Powerhne segment results in over-all average <br />gradient for LU-1 which exceeds 10%. <br />With the exception ofpmexisting roads, Rule 4.03.3(3)(a) specifies that overallgrade for a light use mad shall not be <br />steeper than 10%. Narmtive indicates that the steepest segment of the road (and possibly the entire powerline segment, <br />though this is not entirey clear) "existed prior to powerline construction" : T1Ws would seem to imply that the powerline <br />section of the mad pre-dated Seneca II W1 mine permit issuance, which would make the powerline section of the road <br />exempt from the vertical alignment criteria of 4.03(3)(a). <br />Please clarify whether the powerline section of the road existed prior to initial mine permit <br />issuance, and provide supporting documentation if this is the case, for incorporation into the <br />application. If the powerhne section did exist prior to initial permitting, we would <br />recommend that the "pie-c;dsdW" mad be given a separate designation (perhaps LU-M), <br />since it would be subject to different criteria than the segment ofroad LU-I from the <br />Ri4geliae Access Road up to the Substation. TR48 narrative and maps would need to be <br />revised accordingly. <br />Response: SCC has not been able to find photo documentation that the westerly section of the powerline <br />road existed prior to construction of the powerline; therefore without positive proof, SCC is withdrawing the <br />extreme westerly section from the request for permanency; however the east portion remains in the <br />permanency request. Exhibit 13-28, As-Built Light-Use Road Profiles, and Exhibit 20-2, Postmining <br />Topography and Drainage, have been revised accordingly. <br />5. For newly designated permanent mad segments (e.g. LU-1A and possibly LU-1B), and for road segments with <br />alignments that der fmm original design such as LU-S, appropriate addenda to the original Landowner letters <br />demonstrating landowner agreement with the pertinent road modifications =11 need to be pmvided Please update <br />the landowner request letters section ofAppeadix 20-2.1 as appropriate. <br />Response: Land owner letters are attached that address LU-1, 1A, 1B and LU-5. <br />6. A sentence was added to the secondparagraph under `Powerline and Substation " on amendedpage 20-23, which <br />• states that `Yhe letter fmm YVEA will be submitted when received" The reason for insertion of this statement is not