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As stated in the application, it is very clear that Colowyo had <br />committed to the monitoring plan to provide yearly topsoil balance <br />assessments in order to verify that there was a sufficient amount of <br />soil being salvaged each year to replace a sufficient amount of <br />topsoil on regraded areas. <br />The following table summarizes the four years of information collected <br />during the 1983 - 1986 period and summarized in the Annual Reports. <br /> Acres That Could <br /> Acres of Topsoil Be Reclaimed With Excess <br />Year Salvaged Topsoil Salvage Volume Available Topsoil Acres <br /> <br />1983 37.8 101,257 41.8 4.0 <br />1984 50.0 133,729 55.3 5.3 <br />1985 101.0 300,144 124 23.0 <br />1986 31.0 77,000 32 1.0 <br />TOTAL 219.8 612,130 253.10 33.3 <br />The table clearly indicates that during the four years of monitoring <br />there was sufficient topsoil available to reclaim 15% more acreage <br />than the acreage disturbed. Colowyo has clearly fulfilled the <br />requirements of the topsoil monitoring program. <br />Colowyo has always maintained that the topsoil balance is very <br />favorable at Colowyo. The areas in the Streeter drainage and the <br />drainage to the west provide in excess of ten feet of topsoil material <br />assuring a favorable life-of-mine topsoil balance. <br />The data from the 1985 Annual Report lends further support to this <br />fact. During 1985 there was sufficient volumes of topsoil available <br />to reclaim 23% more acreage than was stripped of topsoi]. During this <br />particular year a substantial volume of topsoil was removed from the <br />Streeter drainage. <br />The Division's assertion that the monitoring data does not indicate <br />adequate life-of-mine topsoil reserves and that the mine is moving <br />into shallower topsoil reserves is contrary to our experiences in the <br />field and does not reflect the monitoring data collected to date. As <br />Colowyo continues to advance to the south into the upper reaches of <br />the Streeter drainage, the amount of topsoil salvaged will be quite <br />favorable. Our monitoring data serves to document this assertion. <br />Therefore, we believe that there is nog justification for the <br />continuation or expansion of the topsoil monitoring program. Colowyo <br />has fulfilled the intent of the topsoil monitoring program and further <br />requests that the monitoring requirement be suspended. <br />-6- <br />