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to be imported. However, the amount of excess topsoil at Trapper is too large to ignore. Second, the Division believes that the existence of such a large amount of surplus topsoil demonstrates that the assumptions that had been used in formulating the various replacement depths may be in error. These assumptions should be reexamined. Third, Trapper has stated, on page 4-263 of the permit application, that excess topsoil can be blended in with the surrounding topography. This is an appropriate plan if a small to moderate amount of topsoil is involved. However, with such a large amount of surplus topsoil, problems with AOC may arise. The Division believes that this much surplus topsoil should be used for redistribution on regraded areas. Based on the above three points, the Division believes that Trapper must submit a plan that addresses the redistribution of surplus topsoil on regraded areas. The Division wishes to make several additional comments. First, Trapper has not applied for phase 2 bond release yet. Therefore, because the Division has not approved the topsoil depths for the areas already reclaimed, the Division can not call all of this topsoil surplus. The Division requests that Trapper provide a discussion of how Trapper has verified the topsoil replacement depths on those areas already reclaimed. Second, it would not be appropriate to reduce the amount of surplus topsoil by reducing the topsoil salvage depth. Any reduction in the topsoil salvage depth, that would leave topsoil in place, would result in the loss of that topsoil. Such a loss would be inconsistent with the regulations. All topsoil must be salvaged. Third, the Division is concerned about how tight a control Trapper has on the quantity of topsoil that has been stockpiled or will be stockpiled. In the 1994 Annual Report, on page 4-262 of Section 5.0, it is stated in footnote (3) that the topsoil replacement yardage could vary by plus or minus 480,800 BCY's. Out of the surplus volume of 1,097,241 BCY'S at the end of 1994, this amount could vary by plus or minus 44$. Even if some of the inaccuracy comes from the plus or minus 2 inches replacement depth, this would account for only a small percentage of the 12 inch topsoil depth for rangeland and 18 inch topsoil depth for cropland. Please advise the Division as to why Trapper can not obtain a more accurate approximation of the topsoil amounts. CC: DAVE BERRY C:\WP51\DRAFT66