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Carol Pahlke December 23, 1980 Page 5 A plan for monitoring zevegetation success should be included in the application. We would suggest monitoring cover by species on an annual or biennial basis. Response: During the period.of liability, studies will be conducted biennially to evaluate vegetation conditions on revegetated areas and specifically to monitor changes in cover of desert wheatgrass and Russian wild rye. Vegetation conditions will be evaluated utilizing the study procedures described in Section 779.19(b). Soil conditions will be mon- itored at least every third year to determine cur- rent erosion features, such as rills, flow patterns, gullies, soil movement and deposition, pedestalling and presence of surface litter. Surface water quality will be analyzed for the parameters listed in Table 14, Kerr Mine Area Surface Water Quality Data. Results of monitoring studies will be included in the annual report for the year in which the studies were conducted. Revised Pages: Revised pages 816-161aaaa and bbbb are attached hereto and incorporated herein by reference. Section 780.21 - Reclamation Plan: Protection of At this time we are not totally satisfied with the Kerr response to OSM's question concerning reconstruction of ephemeral drainages that are mined through. Our major concern would be for the drainage through Pond J watershed. Consid- ering the size of the watershed we are concerned that an improperly reconstructed drainage may result in gullying. This condition would cause downstream sediment loading problems. MLRD will further evaluate this concern when the new post mining topography map with closer contour intervals is submitted. Response: Map 37a Kerr Mine Area Post Mining Topography, was previously submitted as part of the December 4, 1980 response of Kerr Coal to the MLRD November 6, 1980 Adequacy Review.