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<br />Carol Pahlke <br />December 23, 1980 <br />Page 2 <br />Section 779.19 - Vegetation Information <br />With regard to vegetation sample adequacy Kerr Coal has not <br />adequately addressed this concern. Specifically, Kerr is <br />referred to Table 30, and the concerns expressed in MLR's <br />November 6, 1980 letter. <br />Response: Kerr Coal responded to this concern at <br />page 19 of its December 4, 1980 response to the <br />November 6, 1980 Adequacy Review of MLRD. <br />Revised Pages and Revised Tables: Revised pages <br />779-72aaa and bbb, 779-73aaa, 779-60aaa, bbb and <br />ccc, 779-71aaa and bbb, and revised Table 30a were <br />previously submitted to MLRD and OSM as part of the <br />December 4, 1980 response of Kerr Coal to the MLRD <br />November 6, 1980 Adequacy Review. <br />Section 780.11 - Operation Plan General Requirements <br />Kerr Coal has not responded as to why a shorter steady state <br />pit is feasible for Pit No. 1 and 2 but not feasible in Pit No. <br />3. Additional information should be provided to justify the <br />specified steady state pit length, including a discussion of <br />the economics and mechanics on which this decision was based. <br />Response: Neither Pit #1 nor Pit $2 are steady <br />state pits. A steady state pit is defined as a <br />single open pit in which an entire mining operation <br />is confined. Backfilling as well as overburden and <br />coal removal occur simultaneously in a steady state <br />pit through the utilization of two working faces --a <br />working face for overburden and coal removal and a <br />working face for backfilling operations. It is <br />clear from the proposed mine plan and Map 1 and Map <br />33 that, during 1981 and 1982 when Kerr Coal pro- <br />poses to mine Pit #1 and Pit #2, steady state con- <br />ditions are not achieved. During this period, all <br />of the overburden removed from Pit #1 and Pit #2 <br />will be hauled to the existing Marr Pit. As <br />explained on pages 780-87aa through 780-87cc, the <br />lengths of Pit #1 and Pit #2, as designed, were <br />dictated by faulting in Williams and Bush Draws, by <br />environmental concerns, and by the need to provide <br />access through the permit area for Jackson County <br />Road 12E. Because of these constraints, the lengths <br />of Pit #1 and Pit #2 had to be limited to 1800 feet <br />and 1600 feet, respectively. At these pit lengths, <br />