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B. The areas disturbed since 1980 include the sediment pond and associated ditches. These areas will be reclaimed to cropland, therefore, the production requirements of Rule 4.15.9 - Cropland are applicable, The Division suggests that La Plata Coal develop a production standard rather than establishing a reference area. This production standard would be based on production values from the croplands of adjacent landowners in Nay Gulch for the last three years of the bond liability period. La Plata Coal should contact the adjacent landowners and determine whether they would be willing to assist in this way. If the above re vegetation success standards are agreeable, La Plata Coal should incorporate them into the application. 18. This section contains inconsistencies pertaining to the amount and availability of topsoil. Also, page 4.06-1 references the reader to Map 6 fora portrayal of topsoil stockpile location (which does not appear on Map 6). Please correct these inconsistencies. 19, As part of the reclamation plan, a detailed timetable for each step of reclamation is needed. Please incorporate such a timetable into the application, 20. If there is more than one surface owner, La Plata Coal will need to submit letters from the other surface landowners pertaining to their comments on the proposed reclamation plan (see page 87 of the regulations under Rule 2,05.5(2)(b)). 21. La Plata Coal has performed an inventory of the area overlying the proposed workings (affected area) and has determined that no renewable resource lands or structures exist above the proposed mine. La Plata Coal has proposed a three point subsidence monitoring program in Section 29 of the permit area. Each subsidence monument will be located over an area of coal extraction. In order to determine the relative movement of each subsidence monument, it is a commonly accepted practice to establish one monitoring point (benchmark) at a location which will not be affected by subsidence processes. This monitoring point will provide La Plata Coal, as well as the Division, a permanent reference from which to gage movement within the affect area. La Plata Coal may wish to establish this fourth monitoring point (permanent benchmark) in the southern portion of the permit area near the year 1 and year 4 panels. A diagram which depicts a recommended method of establishing subsidence monitoring monuments is enclosed for the applicants use. Application Section 2,06 - (Rule 2,06.8 Alluvial Valley Floors) 1. The discussion on pages 2.06-4 to 2.06-5 needs to be modified to reflect that the sediment pond and associated ditches are within the alluvial valley floor (AVF) of Hay Gulch. -9-