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sediment report. I would contend the output generated and displayed in Table 2 (January 13, 2016) is more of a temporal sediment demonstration than a spatial sediment demonstration between reclaimed and non -mined land. The RUSLE model variables R, K, LS, and P are identical and the averaged cover values are only 4% different between reclaimed and non -mined lands with standard errors for total cover of 2 or greater. Precision of cover data was I%, so one should not have used cover values as input with tenths or hundredths of percent, which gave the RUSLE model a premise of a precise and accurate model. The majority of runoff water and an unknown amount of sediment that are contributing to the problem of erosion and sediment deposition north of the permit boundary is an issue of concern since bond release is based on problems within the permit boundary. Mr. Jack Robeda discussed on November 11, 2015 his concerns and the concerns of the Warnock's who own the property north of the green gate and adjacent the Corley property. This was my concern also, that the amount of sediment leaving the permit boundary, and then the Corley property could be in violation to standards of the Clean Water Act or state or national soil loss tolerance levels. The cause or a major contributing portion of this impact is within the permit boundary and since this area is within the permit boundary then this is an issue that needs to be resolved. Additional RUSLE model demonstrations will not resolve the problem. The second objective stated in the sediment report is to demonstrate that the reclaimed area does not contribute excess suspended solids to streamflow as compared to a non -mined area. According to the letter dated December 31, 2015, EFCI's response states actual water samples are never submitted to demonstrate sediment yields. Therefore, the use of only RUSLE model output fails to demonstrate any value of suspended solids in water that may be transported to a stream or within stream flow. The RUSLE model does not predict runoff volumes so predicting suspended solids in water must be accomplished by other methods not described in the sediment report. Again, the statements claiming demonstration that the reclaimed lands produce less annual erosion or does not contribute excess suspended solids to streamflow compared to non - mined lands was not demonstrated with the sediment report nor the Addendum. Prior to 2011, I observed on two occasions where Mr. George Patterson hired earthwork contractors to clean sediment from Pond 5 and to remove sediment from the downstream end of two culverts that drain under the County Road 92 at the south end of Pond 5. During these two times, sediment from within these culverts were also cleaned out. In addition, the upstream end of these culverts (located in the west road ditch) were also required to be cleaned out at least once. Some armoring of this channel also occurred during this time (over the past 5 years). Before these two clean-out/removal occasions occurred, Pond 5 runoff catchment and sediment retention ability may have been reduced because the upstream end of these two culverts may have been partially or completely blocked. As sediment fills the culverts going into Pond 5, the water flow and sediment contained in the runoff water that is expected to enter Pond 5 and retained within the permit boundary is then instead directed down the west road ditch. This amount of water and sediment yield is variable because it is based on the number of culverts completely blocked or the percentage of partial blockage. When these two culverts are complete blocked, Pond 5 has no hydrologic function for water or sediment contained in the west road ditch. I have not yet observed this at the site.