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Carol Pahlke December 23, 1980 Page 8 To resolve this problem Kerr Coal will have to develop a more suitable plan for this area that will increase the quality and quantity of suitable growth medium and decrease the potential for soil erosion. Methods to improve the growth medium may include but are not limited to: increasing the amount of suit- able topsoil at the site by importing or finding greater depths to salvage and/or supplying a more suitable subsoil either by importing subsoil or identifying and segregating suitable spoil material for use as subsoil. Methods to mini- mize soil erosion may include reducing slopes and slope lengths, using contour furrows, and maintaining suitable infiltration rates by preventing saline conditions from developing at the surface or interface of topsoil. If a conscientious effort is made to develop an alternative plan, we are confident that the issue can be resolved to our mutual benefit with a minimal amount of time. Response: Careful examination of the methodologies proposed by Kerr Coal under Section 780.18 to con- trol ecosion reveal that care has been taken to reduce slope lengths using contour furrows. More- over, the postmining topography as reflected on revised Map 37a indicates that postmining slopes will be less than or equal to premining slopes. The concerns for soil dispersion, lowered perme- ability and sodicity problems in the overburden are unfounded. The physical and chemical data obtained from topsoil and spoil material for the Pit #1 Area confirms that the quality and quantity of the pro- posed plant growth medium is adequate for revegeta- tion success and erosion control. Kerr Coal has presented the results of comprehensive physical and chemical tests on the topsoil and spoil materials from Pit #1 in Table 42a, Soil Chemical and Physical Properties Lab Analysis Kerr North Area, Table 73a, Kerr Coal Overburden Analysis, and Table 76, Texture Analysis of Overburden Raw Data. Examination of these test results for the parameters pH, E.C. and SAR, all of which are factors commonly used to evaluate the salt hazard of soils, confirms the suitability of the Pit #1 topsoil and spoil as a