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PERMIT 79-177, MID-TERM REVIEW MAY 13, 1985 PAGE TWO , CYCC believes that the current opinion of the CMLRD suggesting that a plan for mulching non-rotocleared areas is contradictory to our original proposal and your approval, ignores the fact that the CMLRD has approved our plans for soil stabilization and is inconsistent with the fact that CYCC used the original 1981 submittal and appro- val letters as supporting evidence to discontinue mulching in the CYCC Mine No. 3 Permit Application submitted to the CMLRD in Janu- ary, 1984. As you are well aware, no topsoil areas in the CYCC Mine No. 3 Permit Area ever received the rotoclear treatment, yet the CMLRD's August 2, 1984 "Proposed Decision and Findings of Compliance for the Energy Mine No. 3" on page 43 states: "CYCC has requested the Division to suspend the requirement for mulching. The Division approves the request based upon the proposed soil stabilization plan. This plan involves chisel plowing, seeding of the perennial seed mix in the first appropriate season and contour furrowing." CYCC believes that the record clearly indicates that the practice approved and used at Energy Mine No. 3 was identical to that ap- proved and used at CYCC Mine No. 1. It is in this light that CYCC believes the CMLRD's request that a mulching plan far non-roto- cleared areas is unjustified and contrary to our approved reclama- tion plan. XIV. Backfilling and Grading - Rules 2.05.3(6), 2.05.3(9), 2.05.4(2)(a), 2.05.4(2)(c), 4.09, 4.13, 4.14 1. In response to Division and OSM concerns will rill and gully ero- sion, a number of gullies in Area 1 were regraded and diversion ditches were installed on the slope during the 1984 field season. As a preventative measure, CYCC should revise their soil stabiliza- tion plan to include diversion ditch installation on future re- claimed slopes as well. The plan should include information on size, grade, and location of ditches.