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Carol Pahlke Decembec 23, 1980 Page 3 Kerr Coal insured that the maximum amount of coal would be removed consistent with environmental con- cerns and safe mining conditions. Indeed, to achieve the desired pit depth of 200 feet, together with a haul ramp grade of 108. (the safety limits of the scrapers and haul trucks), it was necessary for Kerr Coal to design the pits so that the entire pit lengths (1800 feet and 1600 feet, respectively) and the entire pit width (approximately 700 feet) could be utilized for the haul ramp. The inability to reach a steady state condition in either Pit #1 or Pit #2 reduced the economic via- bility of these two pits. However, because of the relative proximity of these two pits to the existing Marr Pit, the obligations of Kerr Coal under Federal Coal Lease C-22777 to achieve maximum economic recovery of the coal resource, and the ability of Kerr Coal to achieve a steady state condition in Pit #3, Kerr Coal was able to justify a mine plan which included Pit #1 and Pit #2. It should be empha- sized, however, that but for the existence of Pit #3, neither Pit #1 nor Pit #2 could have been justified under present economic and regulatory conditions. Justification for the length of Pit #3 in the con- text of the steady state condition is set forth at pages 780-3aa, 780-3bb and 7803cc. This justifi- cation will not be repeated here. Revised Pages: Revised pages 780-3aa, bb and cc, and pages 780-87aa through 780-87cc were previously submitted to MLRD and OSM as part of the November 21, 1980 response of Kerr Coal to the OSM Apparent Completeness Review. Kerr Coal should state in more detail where the sedimentation pond sediment and embankments will be disposed of off the permit area. Res~o-nse-: At this early date, it is impracticable orKerr Coal to identify what disposal areas may be available for disposal of sedimentation pond sedi- ment and embankment material off of the permit area.