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concept is then for the dredge to mine in a large circular fashion, backfilling and reclaiming behind i[ as it moves away from the initial cut and overburden stockpile, and eventually ending up back next to the overburden pile. Since approximately 25% of the mined material is removed and sold as product, whenever a phase is completed, a void is left which will become a permanent lake. [n this mining plan this void will be divided into two separate lakes. When [Ite dredge reaches its farthest point away from the initial overburden pile, a lake will be left at that point, and when the initial overburden pile is backfilled into the final cut, a lake will be left at that location. In order to maintain a reasonable financial warranty, the backfilled area immediately behind the dredge is regraded, topsoiled and revegetated as soon as possible so that it is not counted as disturbed area. In general, the Division has no problem with this mining concept, however, there are a couple of concerns that were raised after the pre-operational inspection was conducted. Using the active phase as an example, the general direction of mining is in acounter-clockwise fashion moving from east to west, [hen south, then back east and eventually north again to end up next to the overburden stockpile. However, for some reason the dredge was moved diagonally from the western edge of phase I to the southeast eventually ending up almost directly south of the overburden stockpile. As a result of this "shortcut", the screening deck was also moved and now sits right in the middle of the backfilled and regraded area just west of the overburden stockpile, along with the slurry line from the dredge to the screening deck, the slurry line return line into the lake, and the conveyor over to the prep plant area. This is a fairly sizeable area that has been backfilled, regraded and in some cases topsoiled. What the activites that have occurred in Phase l serve to illustrate is that some mining related activities are going to be conducted on the regraded area and topsoil should not be replaced until this activity is completed, and if topsoil has been replaced and the area is once again needed for mining related activities, the topsoil must be re-stripped and stockpiled. In observing what has occurred in Phase 1, it seems that even though areas that have been mined and backfilled can then be re-graded, it may not be possible to topsoil and seed these areas until almost all mining in a phase is completed. This is due to the fact that as mining progresses, the suction dredge support equipment (slurry lines, screening deck, conveyors, etc.) are moved around on the backfilled and regraded areas as the dredge moves, and until the dredge and lake aze almost back to the beginning point, all areas that have been backfilled could be used in support of the active mining process. What this ultimately means is that some areas may not be topsoiled and seeded as soon as backfilling is completed. As a result, topsoil handling procedures may need to be reviewed since some of the proposed live-handled topsoil may now have to be stockpiled until more of the mining phase is completed. In addition, the total maximum disturbed area will probably need to be enlarged to account for the delay in final reclamation that will occur on certain backfilled and regraded areas until mining has progressed to the point that these area will definitely not be re-affected. Also, in reviewing the proposed plan it seems that once Phase 1 is completed, it may be possible to transition into Phase 2 by just continuing to operate out of the "Final Lake" that will remain in Phase 1. This would eliminate the need to construct another overburden sand pile which would also greatly reduce the reclamation and financial liability of the mining plan since reducing the initial overburden sand pile by putting it back in to the dredge lake is the single largest cost associated with the reclamation plan. If this pile could be permanently eliminated, the overall reclamation bond would basically be reduced by half on the remaining mining phases. All of this is dependent on whether or not the remaining lake is large enough to continue operating the dredge after backfilling of the initial overburden stockpile is completed. This is something that will have to be evaluated as Phase I nears completion. However, it may be something [hat you want to include as a possibility with [his amendment so that if [his becomes possible in