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This operation is a function of the topsoil lay down and reclamation process rather than a topsoil stockpile operation. Because the piles aze re-spread eazly the next yeaz before any seed has a chance to produce any significant growth, the piles aze not seeded. 'These piles are isolated and generally not located near active mining activities so, just as reclaimed areas do not have topsoil signs, these piles located adjacent to the reclaimed areas were also not posted with signs. During the adequacy review process for PR-O1 (see the attached excerpt from the October 4, 1991 letter), the Division acknowledged that this altemative practice is "a good idea to increase the efficiency of topsoil movement, get topsoil replaced over regraded spoil more quickly and provide a better topsoil resource for reclamation purposes." To clarify this alternative practice and because the regulations neither specifically prolu'bited or provided for this practice, the Division requested that Colowyo modify the Permit to include this practice. To comply, this alternative practice was fiuther defined on page 2.05-26 of the Permit {a copy is attached herein). Note that there was no discussion to require seeding, signs or other requirements. During the time of the discussion regazdmg this practice it was acknowledged that such practices were applicable to the permanent topsoil stockpiles and not applicable to the piles located on the reclaimed areas. The Division's "Proposed Decision and Findings of Compliance for a Permit Revision" dated July 23, 1992 (revised} also addresses these alternative procedures for the topsoil (see the enclosed excerpt from the document). In the Division's findings to approve this alternative practice it was stated that `°The Division believes this method oftemporary storage oftopsoil better protects the resource than temporary storage in established topsoil stockpiles followed by subsequent haulage and redistnbution (4.06.1(2))." Clearly, Colowyo has addressed the topsoil handling procedure through the permitting process and the Division has praised the practice as superior to needless rehandle of the topsoil resource. 2) The Ahernative Practice Did Not Include Seeding and Top,~gil Signs. During the discussions with the Division regazding these alternative topsoil practices, the issue of signs and seeding was addressed. It was recognized that, given the short time the piles were in place, application of seed simply did not make sense. Erosion could be controlled by the brush included in the topsoil and leaving the piles in a rough condition. We also located the piles where they would be less susceptrble to water erosion. It was also recognized that since these piles were not stockpiles, were generally located away from mining activities and functioned as an extension of the reclaimed aeeas, signs were deemed not necessary. For these reasons seeding and sign requirements were not proposed or included by either Colowyo or the Division during the discussions or permitting of the alternative practice. Needless to say, our opinion remains unchanged. Seeding or placiag signs on these piles 2