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INTEROFFICE MEMORANDUM TO: 'f'Obf KALDENRACH FROM: JANG; I`BIN~~` (~ SUBJECT: h'ING bilN II, C~ 35, PI2- 8 DATE: 12/16/2005 CC: DAN iIERNANDP7 I have reviewed National King Coal, LLC's application for a permit revision, PR-08 for compliance with Rule 2.04.9, 2.04.10, 2.05.4, 4.06, and 4.15. I have the following observations: Estimated disturbance area for King II Mine, 19.9 acres. Post-mining land use is proposed as rangeland, fish and wildlife habitat, and undeveloped. Pre-mining community is primarily Rabbitbrush/Big sage mixed shrubland with a small, less than three acres, of Pinyon Juniper woodland. The reclaimed azeas will be compared to rabbitbrush/Big sage mixed shrubland for reclamation success. Due to the small area of Pinyon Juniper woodland proposed for disturbance, the operator will not attempt to compare reclaimed azeas to this vegetation type but will use the rabbitbrushBig sage mixed shrubland as the sole reference azea. This is acceptable in accordance with Rule 4.15.7(3)(iii). I reviewed the seed mix proposed for the King II Mine on page 8 of Section 2.05.4. The proposed seed mix is appropriate and acceptable. There aze differences in the currently approved seed mix for King I Mine and the proposed seed mix for King II Mine. These differences account for the south and southwest exposures on the proposed King II Mine versus a north and northeast exposure on the King I Mine area. The proposed seed mix for the King II Mine site also reflects baseline vegetation. Reclamation success for diversity. Relative cover will be used to determine species diversity A minimum of six perennial species shall be present in the final reclamation community. No single species shall comprise greater than 40% relative cover. Four of the six species shall be native species. Three species shall be grasses. Grass species shall contribute greater than or equal to 2% rel. cover One shall be a forb. Forb species must contribute greater than or equal to 1 % relative cover to count towards the diversity standard. Two species shall be shrub species This diversity standard is acceptable Topsoil will be replaced to a depth of 12 inches. Only the Umbazg soils will be salvaged due to limiting factors of the other two identified soil types. The operator commits to conducting soil fertility testing two or three growing seasons after seeding occurs. Should soil testing indicate that soil fertility is deficient, appropriate fertilizer will be applied at that time. This is acceptable under Rule 2.05.4(2)(e)(vii). Please find the following adequacy concerns that I have identified during my review: