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D <br />Mr. Brock Bowles <br />November 13, 2015 <br />Page 2 <br />2. On permit Map 2.05.4-7 WFC, Lloyd & Benson West Properties Topsoil Replacement <br />Plan, the average topsoil replacement depth is to be 21 inches (15-24"). The reported <br />topsoil depths on the SL -15 application Map 3 average is 21.96 inches. During the <br />inspection, 5 holes were dug with a backhoe to verify the topsoil depths and these depths <br />averaged 30 inches. Please explain why the average topsoil replacement depth exceeds <br />the required average. <br />Response: The average depth of 30 inches has been more than a sufficient depth to <br />provide a proper rooting zone and successful vegetation establishment on the WFC, <br />Lloyd, and Benson West properties. Also, with the overall topsoil balance for the <br />remainder of the reclamation that will occur at the New Horizon Mine, adequate topsoil <br />is available to reclaim the WFGJohnson property and achieve successful vegetation <br />establishment within the required 10 year period. <br />3. The irrigated pasture of the Benson property has differential settling. Several areas have <br />settled at a greater rate than other areas causing `potholes' to form. Surface runoff water <br />from the irrigation system collects in the potholes resulting in standing water and <br />saturated soil around the pothole. The hayfield was cut prior to the inspection and several <br />of the potholes had been avoided leaving standing hay/alfalfa. These potholes are not <br />consistent with the post mining topography approved in the permit and need to be <br />repaired. WFC is currently working with DRMS on a plan to repair the potholes. The <br />following rules should be considered when creating a plan. Rule 4.15.7(5)(d) states that <br />leveling is considered a normal husbandry practice for an alfalfa or grass hay cropland. <br />For the potholes that can be repaired by only having topsoil added, it will be considered <br />leveling and will not reset the liability clock. For the potholes that need to have the <br />topsoil removed, overburden filled in and the topsoil replaced, it will be considered a <br />repair. Rule 4.15.7(5)(a) allows for up to 5% of the acreage initially revegetated during <br />any one year to be repaired without reinitiating the liability clock. <br />Response: A plan has been developed and presented to Mr. Brock Bowles by Mr. Frank <br />Ferris (WFC) on October 20, 2015. As noted in Mr. Bowles October 20 and 21, 2015 <br />inspection report, WFC plan demonstrates compliance with Rules 4.15.7(5)(d) and <br />4.15.7(5) (a). <br />4. On the north facing slope of the WFC/Benson property between ponds 9 and 12, many <br />rills and a few gullies have formed. The soil stability of this area needs to be addressed <br />AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER <br />A Touchstone Energy' Cooperative A'ItI <br />r` <br />