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- 6 - <br />establishment and plant community diversity. When considering the <br />success of reclamation in an area, the Division must consider aspects of <br />reclamation other than the two stated KCC objectives. The Division <br />believes that KCC has failed to demonstrate that 6 inches of replaced <br />topsoil will meet the reclamation goals of protection of the replaced <br />topsoil resource from subsequent wind and water erosion since the <br />established plant community will probably exhibit less plant cover and <br />production (Rule 4.06.4(2)(d)). KCC's plan for salvage of only 6 inches <br />of topsoil across all soil types fails to meet the requirements for <br />considering site specific soils information when determining depth of <br />topsoil salvage (Rule 4.06,2(2)(b)). KCC's proposed plan has been <br />supported by literature that seems to support the contention that less <br />topsoil replacement will promote better reclamation. Rather, most of the <br />studies (when examined more closely) have documented the phenomenon of <br />increasing plant cover and production being positively correlated with <br />replaced topsoil thickness. <br />Studies on topsoil wedges in the Great Plains have suggested that no <br />increases in plant production and cover occur after the topsoil thickness <br />exceeds the average annual soil moisture recharge depth. The Division <br />suggests that Smith's (1966) stated average depth to lime of about 24 <br />inches (page 2.04.9-31) indicates the average soil moisture recharge <br />depth in this area of North Park. If this is indeed the case, 24 inches <br />of topsoil or proven topsoil-like materials ("underlying other layers" of <br />the approved Permit Application) may be an appropriate replacement depth <br />on all mined areas. Alternatively, KCC could figure out what total <br />volume of suitable topsoil material was available and commit to salvaging <br />and replacing all this material as required by Rule 4,06. This type of <br />demonstration of total topsoil availability is mostly documented in <br />Tables 42, 43a, 47, 48, 57aa, 58aa, 69a, 71 and 72a in the approved <br />permit. Modification of these tables to fit the proposed mine plan would <br />be appropriate. <br />29. Solid lines on Map 23 - Mine Area Soils denote either soil type <br />boundaries, disturbance lines, or both. It is impossible to tell whether <br />the solid lines are meant as disturbance boundaries for the pits. If <br />they are, then pit boundaries sometimes go outside of the disturbance <br />boundaries. In any case, the meaning of these lines must be clarified or <br />changed. Accurate checks on amounts of topsoil available are not <br />possible at this time until these boundary line problems are clarified. <br />The soils map must have clear disturbance boundaries marked in order to <br />comply with Rule 2.04,9(1)(c)(ii) and show the soil horizons and areas <br />proposed for salvage. <br />30. Soil type delineations must be added to Map 33 - Mine Area Soil Removal <br />and Storage and Map 40 - (dine Area Soil Replacement and Reveaetation tc <br />comply with Rules 2.04.9, 2.05,3(5) and 2.05,4(21(d), This will allow <br />the Division to verify the topsoil volumes on Tables 61, 62, and 67, <br />31. KCC has requested (on pane 4.06-1) a variance from topsoil salvage in <br />areas where engineered diversion ditches will be constructed. The <br />Division will consider such a request. However, KCC must specifically <br />