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-5- By far the most limiting factor with respect to topsoil suitability was high clay content. Since both overburden and topsail show high variability in parameters analyzed with respect to location in the pit and surface position (topsoil in swales versus upland areas), KCC must, at the least, maintain the baseline data and suitability ratings for both overburden and topsoil as previously used and approved so the Permit Application Package complies with Rules 2.04,6 and 2,05,4(2)(d). The approved tables that should be included in the proposed permit revision package are Tables 43a, 46, 48, 73a, and (if applicable) 78, Please revise Table 5a (currently Table 15) to reflect all of the baseline information. 24. It is impossible to verify Table 34 - Topsoil Suitability Comparison (with respect to overburden values) since the baseline data used to compile the table cannot be found in the present Permit Revision document. The Division believes that Table 34 cannot be used to determine specific management practices for specific materials in the field. For the reasons stated above and in previous questions, Table 34 should be removed from the permit revision package because it does not adequately or accurately portray actual field conditions at the Marr Mine. 25. Statements in Permit Revision 1 indicate that, in some cases, Wyoming DEO or Montana DSL suitability criteria will be applied and, in other cases, these criteria are not applicable. What specific criteria will KCC use to determine topsoil suitability as a plant growth medium? 26. In the discussion to support the contention that less topsoil replacement will enhance the reclamation objectives, Marr baseline data and several studies are cited. Although not all the papers cited were read, some have been reviewed and comments are offered, in the accompanying Appendix A. The contention that 6 inches of topsoil will enhance reclamation of the mined areas is discussed in section 4.06 of the Permit Revision Package. However, upon closer examination of each piece of evidence presented by KCC, as noted in Appendix A, the Division has found support for Rule 4.06 which requires that mine operators salvage all available topsoil. 27, a. On page 4.06-11, KCC states that "...the available data indicate no significant increases in plant response for topsoil depths greater than two inches." To what available data is KCC referring to? b. In the second paragraph of page 4.06-11, KCC refers to a study conducted in the Piceance Basin evaluating the effect of soil mixing versus replacing soils in reverse order. To which study is KCC referring? 28. The Division must consider reclamation to be successful when an area has been reclaimed according to the standards put forth by Rule 4. KCC has attempted to demonstrate that 6 inches of replaced topsoil over spoil, no matter what the specific quality of these materials, will achieve the stated reclamation goals of increasing Wyoming big sagebrush