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Rob Zuber December 31, 2015 Page 2 successfully bond released through the appropriate permitting action. As you are aware, a permanent road has no requirement for topsoil redistribution (Phase II) or revegetation (Phase III). All reclamation bond monies were successfully released for the Monarch fan road as a result of final approval of SL -02. However, EFCI acknowledges that tracking of the areas (acres) associated with these permanent features is administratively necessary and desirable, and as such, EFCI included acreage values for these features as part of the application (see Southfield SL -03 acreage table). The acreage table clearly indicates via the *footnote that the 68.6 acres bond release granted through SL -02 includes the road to the south fan. The acreage for this 1.2 mile portion of road, although not specifically called out in the SL -02 written findings, is clearly part of the greater 68.6 acres that were bond released in SL -02. 3. Page 2 of Appendix D refers to Attachment 1, but this appears to be missing from the application. Please provide this. A relate question: how does EFCI explain the fact that the LS factors for the reclaimed areas and the non -mined areas are identical? RESPONSE: EFCI used the same basic format for the sediment demonstration calculations as was previously used and accepted by the DRMS for the loadout pond removal demonstration. However, for SL -03, rather than present the calculations as a separate attachment, all of the calculations, values and/or formulas for each factor were included under the discussion of each factor rather than included on a relatively meaningless attachment. The reference to a separate "Attachment 1" was in error and has been removed from the text. Replacement copies for both the loadout and the mine site sediment demonstrations are enclosed. It should be noted that no sediment demonstration was necessary for the loadout as part of SL -03, as the sediment demonstration for removal of the loadout ponds had been previously approved by the DRMS. However, EFCI included a sediment demonstration in SL -03 for the loadout and incorporated the most current, up-to-date information from the 2013 and 2104 vegetation sampling as a courtesy. The related question about identical factors for the LS factor is reasonably straight forward, yet requires some discussion, especially given the scrutiny of landowners and others who may not be trained in the technical aspects of sediment modeling. In my previous 21 -year professional employment, I was the staff expert on surface water modeling for both operational and bond release purposes. I reviewed dozens of sediment modeling comparisons for Phase II bond release and possibly hundreds of hydrologic models using state -of -the art software such as SEDCAD and HEC -1, as well as "hand calculations" using USLE and RUSLE. In no case did an operator ever submit actual water samples to demonstrate sediment yields, the reasons for which are too numerous to mention. Sediment modeling was used exclusively for the demonstration required for pond removal and Phase II bond release purposes. Development of early empirical soil erosion models started more than 75 years ago with efforts by Cook (1936), Zigg (1940), and Smith (1941). The Universal Soil Loss Equation (USLE) was developed in 1965 by Wischmeier and Smith. After improvements and a new evaluation of the original USLE database, in 1993, (Renard, et al) developed the Revised Universal Soil Loss Equation, which was used by EFCI in the sediment demonstrations for SL -03.