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hh~. Jeff Deckler October 21, 1985 Page Z Furthermore, if quantitative cover data were required for Phase II, it would be meaningless without species composition or diversity data to ensure the cover was not composed of weedy species. Since cover and production are related vegetative parameters, it can be said that if statistically adequate and diverse cover have been achieved, it is probable that production would be adequate, ar nearly so. If this is r~+,+red for Phase II bond release, then there would be justification for having a Phase III since the reclamation objectives would have been met. Bond release would then be a two phase procedure and not three. Addition- ally, if erosion control is the objective of Phase II, ground cover and not vegetative cover, should be the parameter evaluated. This would include mulch and cover crops, as well as live perennial vegetation. If this were the Phase II standard, Phase II could be acccag~lished after all reclamation activities have been completed aryl there would still be justi- fication for having three phases. According to Webster's New World Dictionary "successful" is defined as: "1. Coming about, taking place or turning out to as was hoped for; 2. having achieved success". "Establishment" is defined as: "1. As establishing or be established; 2. a thing established". "Establish" means "to cause to be or happen, being about". By causiry the successful establishment of the reclamation program and by controlling erosion and potential offsite erosion, Sun Coal Company believes the baclcfilled area has been reclaimed in acoordanc;e with Phase i and Phase II boQrd release criteria by topaoiling, reseeding and fertil- izing the dlaturbed area. Sun Coal, therefore, feels it has achieved the intended goals of both Phase I aryl Phase II band release in the backfilled pit area and is requesting the release of 85AS of Sts band irr that arm. HAUL ROAD An agreement with the landovaver and Sun Coal Company (dated October,1983), has resulted in the approval of retention of the haul road as an alternative post-mining land use [pursuant to Rule 4.03.1 (f)(i) and (ii)). Acceptance of this land use alternative, at the landowner's d 4~~J. ..J: 'l„,~