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- 12 - Kerr Tipple: The upland portions are to receive sagebrush and rabbitbrush transplants at a rate of 6800 stems per acre. The flat lowland areas are to receive willow transplants at a rate of 200 plants per acre. Kerr t4ine Site: Sagebrush and rabbitbrush individuals are to be transplanted at a rate of 200 stems per acre. Page 780-79 contains a commitment for transplanting seedlings in the first spring following seeding of the perennial seed mix. In light of Kerr's difficulties in attaining a woody plant density near the 2000 stem standard, it seems appropriate that these commitments be maintained. For the Kerr mine site it would be acceptable if transplants were taken from adjacent undisturbed areas which are slated to be disturbed soon. Sealing of Drilled Holes and Underground Openings - Rules 2.05.4(2)(a) and 4.07 50. Rule 4.07.3(2) specifies that drill holes completed in aquifers will be sealed with concrete in the water bearing zone(s) and for twenty feet on either side of those zones, installing a plug ten feet below the ground's surface, and cementing seven feet up from there and backfilling the remaining portion with cuttings. While 4.07.1 of the permit application alludes to that practice, Section 2.05.4, page 2.05.4-53, predominantly describes parts of the accepted regulatory practice for abandoning dry holes per Rule 4.07.3(1). Please revise Section 2.05.4 to reflect the performance standards of Rule 4.07. Coal Processing Waste - Rule 4.11 51. Rule 4.11.4(2) specifies that non-coal wastes shall be placed in a 'designated' site in the permit area. Page 4.11-1 indicates that waste will be disposed of in a 'suitable' disposal location per Section 2.5. On page 2.05.3-17 there is reference to a 'designated' pit disposal area, but no map citation. Please specify the location of one or more waste sites and commit to designs in accordance with 4.11.4. Backfilling and Grading - Rules 2.05.3(6), 2.05.3(a), 2.05.4(2)(a), C1, 4.UY, 4.13 a 52. The Division has carefully considered the backfilling and grading plan in the permit revision and finds that it does not meet the criteria of approximate original contour (AOC) The definition, found in Rule 1.04(13) requires that the post-mining topography resemble the pre-mining topography, that it blend in with the surrounding landscape and that it should result in the elimination of highwalls and spoil piles. The general topography of the mine plan area consists of broad rolling ridges, gently sloping valleys and steep localized features. A prominent ridgeline runs in a northerly direction, paralleling the west side of the mine pits in the southern part of the mine permit area. This ridgeline flattens and turns to the northwest near the center of the property where it is cut by several ephemeral and intermittent stream channels producing broad sloping valleys. This northern area is depicted in the accompanying pre-mine topography perspective drawing.