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Carol Pahlke <br />December 23, 1980 <br />Page 11 <br />salvaging and stockpiling of the B horizon for <br />redistribution between the A horizon and spoil, and <br />that it may actually be more beneficial not to <br />reapply this heavy-textured material as a separate <br />layer. <br />Site-specific data concerning revegetation on this <br />soil type (Coalmont X73) was collected and analyzed <br />in the summer of 1980. The area where data was <br />collected was the abandoned Monolith strip mine 3 <br />miles west of Pit #1. Like the soil in Pit #1, the <br />soil type in the area sampled is Coalmont (X73). <br />The Monolith strip mine was abandoned in 1952 and <br />left to be naturally revegetated. When sampled in <br />1980, Kerr Coal found that the plant cover on this <br />site was 22.6 percent and that plant production on <br />this site was 418.8 pounds of air-dry forage per <br />acre. In comparison premining vegetation data col- <br />lected by Kerr Coal from the Pit #1 Area disclosed <br />that plant cover was 21.3 percent and that plant <br />production was 226.3 pounds of air-dry forage per <br />acre. <br />The revegetation success achieved at the Monolith <br />strip mine on a Coalmont (X73) soil type without <br />implementation of any reclamation practices <br />provides strong evidence that the Coalmont {X73) <br />soil type found in Pit #1 can be successfully <br />revegetated. Indeed, since the site sampled at the <br />Monolith strip mine achieved its revegetation <br />naturally, a conclusion that Kerr Coal will be able <br />to achieve similar success at Pit #1 utilizing the <br />proposed reclamation practices is more than <br />justified. <br />Finally, Kerr Coal's topsoil removal and replace- <br />ment plan is entirely consistent with the Perfor- <br />mance Standards of 30 CFR 816.22 - 816.29 and State <br />Regulation 4.06. Specifically, Kerr Coal is <br />expressly committed by its Permit Application to re- <br />moval of all available topsoil from disturbed areas <br />within the Permit boundaries. All salvaged topsoil <br />will be redistributed over the backfilled and re- <br />graded overburden to a minimum depth of 6 inches in <br />the Pit #1 Area. This depth of topsoil replacement <br />is in accord with the requirements implicit in 30 <br />CFR 816.22 and, as demonstrated here and in pre- <br />viously submitted materials, will accomplish the <br />reclamation results specified in 30 CFR 816.24(b) <br />and State Regulation 4.06.4(2). <br />