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Page 7 Keith Kirk, Mike McCarthy January 2, 1980 31. Section 816.114(c) - The regulatory authority must approve your request for the use of an annual grain mulch in place of straw mulch. The applicant should submit site specific data which demonstrates that an annual grain mulch is superior to a straw mulch for erosion control. Once this information is received a determination can be made on the effectiveness of the annual grain mulch. This information should be available from the study undertaken by EFC at the 20900 lease site. 32. Section 816.116 (Revegetation: Standards for success) - See comments in previous memo. 33. Section 816.132(b) (Cessation of Operations: Permanent) - From the narrative it appears that a final pit may be used to receive any gravel or asphalt that may result from reclaiming the surface facilities areas. It appears that some form of surface facility will be required to service the equipment carrying out the reclamation activities. Please discuss what facilities will be required to service the equipment needed to com- plete reclamation and the outcome of those facilities. Also, the appli- cant indicates that topsoil was not salvaged from these areas, therefore it is doubtful that topsoil will be available for redistribution upon those areas. I suggest that additional suitable subsoil be salvaged from the current and future mining areas to aid in the reclamation of this area. 34. Section 816.133(c)(1) (Postmining land use) - The applicant has not submitted proof of local government approval. The applicant has failed to submit the document required in 816.133(c)(9)(i), as part of the area will be returned to cropland. 35. Section 816.150 (Roads: Class I: General) - As stated in the prior memo, all class I haul roads must be accurately portrayed on a map. Also, the location of all temporary sediment control structures should be included on the map. In addition, the following information should be submitted for the various haul roads; cut and fill areas, toe of the outslope for the fill areas, and drainage ditches for the cut and fill sections. The applicant should indicate the volume of box cut spoil that will be used to construct the road and where this material will be placed during the reclamation of the roads. 36. Section 816.152(c)(2) - They are asking for a variance from this require- ment and I recommend that we approve this request. 37. Section 816.154 (Roads: Class I: Surfacing) - Should the existing roads also be surfaced with gravel. If not, do we need information which indi- cates the material used on the existing road is sufficient for its use.