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c) Text on page 5a and notation on Exhibit 19-1A have both been amended to specify completion of "B" Pit backfilling and grading in 2004, rather than 2003. The subject area of the "B" Pit has been open since at least the mid-1990's, and was originally approved to be left open to allow for removal of a small amount of remaining coal. The deadline for coal removal and backfilling has been previously extended by the Division on several occasions. Due to stability concerns, the operator has indicated that no further coal recovery will be attempted in the "B" Pit. The Division is not willing to approve further extensions of the "B" Pit reclamation deadline. Please revise the text and Exhibit 19- 1A tospecify completion of "B" Pit backfilling and grading in 2003. d) Based on review of the Operations Plan (Exhibit 12-3) and Backfilling and Grading Schedule (19-1A), the "worst case" disturbance would likely occur during 2005. At this time, pits would be open in 3 separate areas, including the entire length of the IIW South Wadge Pit variance areas scheduled for backfilling and grading in 2005 through 2007. The IIW South Wadge Pit variance areas denoted in the bullet points at the top of page Sb, and depicted on Exhibit 19-1A comprise a total of 10,400 feet of open highwall that would be open atone time (almost 2 miles of highwall). This includes approximately 2000 feet of highwall along the ridgeline at the north end of the South Mining Block, which has been open since 2002 and would not be backfilled until 2005, under the proposed plan. Narrative on amended page 5b states that although this variance request consists of 12,500 feet of highwall, it should be realized that only a limited portion of this highwall footage would be open beyond the 180 day regulation at any one time. For clarification, please amend this statement to specify that the maximum cumulative pit length to be open beyond the 180 day regulatory limit at any one time would be 10,400 feet. e) The description of pit backfilling sequence with respect to maximum number of spoil ridges alludes to so many variables that might result in up to 4 (or more) spoil ridges behind the active pit, that it is difficult for us to define the "worst case" situation for bonding purposes without making very conservative assumptions. Please provide appropriate supplemental narrative and maps to clearly define and delineate the worst case disturbance with respect to number and length of spoil ridges that would occur within each of the three pit areas. f) Narrative on pages 5 and Sa refers to the to the potential for the occurrence of more than four spoil ridges behind the pit being worked. This is in apparent contradiction of Rule 4.14.1(1)(c) which requires, for area strip mining, that rough backfilling and grading shall not be more than four spoil ridges behind the pit being worked. The rule also requires rough grading within 180 days of coal removal, but allows the Division to grant a variance to allow for additional time based on a detailed written demonstration. The rule does not indicate that a variance can be granted to allow for more than four spoil ridges behind the pit being worked. Please amend the narrative on pages 5 and 5a to clarify that backfilling and grading operations will be conducted to ensure that there will be no more than four spoil ridges behind the pit being worked. 22. Amended Exhibit 19-1A Bac~lling and Grading Schedule 11-W South, depicts postmining contours in green. The postmining contours were not extended into the proposed expanded Sage Creek/Wolf Creek pit area at the extreme southern end of the permit area, as would appear to be appropriate. Please amend the map as appropriate to accurately depict proposed postmining contours.