2013-01-29_PERMIT FILE - C1981022A (3)

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Section - 2.05.3 activities, to control or prevent siltation, and reduce water pollution and prevent damage to public or private property, we routinely have construction equipment onsite to conduct active maintenance to address any issues caused by our activities or facilitate improved vehicular passage after inclement weather. Oxbow routinely conducts maintenance by grading, adding rock in soft spots, adding straw wattles and straw bales, seeding, drainage pipes, installing water bars, etc. We anticipate our maintenance activities will be ongoing during the time that we are using the roads. During the winter months and spring snowmelt conditions, Oxbow routinely uses a snow cat to access GVB sites rather than trying to keep roads open for wheeled vehicles. In comparison, other road users conduct little, if any, comparable road maintenance activities. For example, Oxbow conducts spring road repairs to provide maintenance to road damage from previous fall hunting activities. Hubbard Creek Canyon Road - Portions of the Hubbard Creek Canyon road, which provides public access, were straightened, graded, and gravel-surfaced by U.S. Steel to the configuration shown on the Hubbard Creek reclamation plan drawings (included in Exhibit 2.05-E5, Reclamation Details) to improve access to the Upper and Lower Hubbard Creek ventilation sites. Portions of the existing inactive and partially reclaimed surface facilities are within 100-feet of the Hubbard Creek Canyon road. Relocation of portions of the existing road in the vicinity of these facilities was completed to minimize mining-related impacts on the road and to avoid interference with public use of the road. The road, which is currently utilized only for public access, periodic inspection of the reclaimed areas, monitoring, and landowner/grazing leasee access is owned and maintained by the mining-related impacts on the road and to avoid interference with public use of the road. The road, which is currently utilized only for public access, periodic inspection of the reclaimed areas, monitoring, and landowner/grazing leasee access is owned and maintained by (included in Exhibit 2.05-E5, Reclamation Details) to improve access to the Upper and Lower Hubbard Creek ventilation sites. Portions of the existing inactive and partially reclaimed surface facilities are within 100-feet of the Hubbard Creek Canyon road. Relocation of portions of the existing road in the vicinity of these facilities was completed to minimize mining-related impacts on the road and to avoid interference with public use of the road. The road, which is currently utilized only for public access, periodic inspection of the reclaimed areas, monitoring, and landowner/grazing leasee access is owned and maintained by the County and U.S. Forest Service (upper portion of road beyond Forest Boundary), except during the winter. The Lower Hubbard Creek facilities have been removed and associated disturbance areas reclaimed. The existing Upper Hubbard Creek facilities are currently inactive, although the potential exists that they may be utilized in conjunction with future mining activities. Old State Highway 133 - Old State Highway 133, which connects to the new highway approximately 3 miles east of the mine, runs along the north side of the North Fork of the Gunnison River, ties in with the Sanborn Creek Mine access road, and provides both alternate access to the mine site and access to the Substation No. 3 and C-Gulch ventilation site. This road was constructed prior to 1976 and is owned by the State of Colorado. OMI maintains the road as a light-use road for mine access. Other Access and Light-Use Roads - Various plant roads in the Elk Creek coal handling, support, and ancillary facilities; East Yard: and Sanborn Creek Mine areas were constructed prior to 1976 and continue to be utilized as access roads in support of ongoing mining operations. These roads, which total approximately 1.0 miles in length, are relatively flat (< 5 percent grade), with road widths varying from 15 to 20 feet. Drainage control for these roads is provided by the drainage and sediment control systems for the corresponding facilities areas. Since the roads are within the disturbed area in accordance with Rule 4.05.2(4), construction certification is not required and the design and construction standards specified in Rule 4.03.1(3) are not applicable. Road locations are shown on the Mine Facilities Map, (Map 2.05-M1). TR-63 2.05-29b Revised June 2009 ?v9