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Please amend narrative schedules, tables, and Exhibits of Tab 19 as appropriate, to clarify time frames,
<br />definitions, and deadlines for rough backfilling and grading, final grading, and final drainage channel
<br />construction.
<br />30. Narrative on page 10 of Tab 20 addresses various design and geomorphic considerations pertinent to
<br />postmining dminage channels. Review of channel profiles on Exhibit 20-5.9 indicates certain apparent
<br />discrepancies when compared to the geomorphic considerations listed, and the geomorphic criteria of Rule
<br />4,05.4. Narrative indicates [hat average stream gradients will exhibit a concave longitudinal profile and that the
<br />channels will not exhibit any nick-points. Channels PM-3 and PM-4 appear to contain distinct convex slope
<br />segments with abrupt gradient increases in their lower sections. Channels PM-I and PM-2A appear to present
<br />relatively straight, rather than concave profiles, and PM-2, which does appear to present anover-all concave
<br />profile, also appears to include a couple possible nick-points, and a gradient increase near its lower end.
<br />Please address these apparent inconsistencies, and provide amended designs as appropriate to ensure
<br />compliance with the applicable geomorphic criteria of 4.05.4.
<br />31. Channel PM-4, for which a profile is provided on Exhibit 20-5.9, is not depicted on the Postmining
<br />Topography Map, Exhibit 20-2A. Also, on the amended Exhibit 20-2A, there is a long narrow strip to the west
<br />of upper PM-2A, where contour lines appear to have been deleted. A smaller rectangular area on the lower
<br />portion of PM-2A is also blank (no contour lines). Please address these discrepancies and amend the
<br />exhibit as appropriate.
<br />32. Tab 23, Fish and Wildlife Plan, contains a discussion of final grading methods that will be used [o create
<br />topographic habitat diversity within "interstream" areas, resulting in "humps, small swales, and other
<br />topographic diversity" that cannot be accounted for on a 1":400' scale map. The lack of such small scale
<br />topographic variation on some areas final graded in recent years has been previously noted by the Division. In
<br />order to ensure that the objective of small scale topographic variation will be incorporated in future
<br />reclamation grading, the Division requests that the postmining topography map Exhibit 20.2A be
<br />amended to include a notation indicating that "inter-stream areas of the final graded surface will
<br />contain irregular undulations, humps, small swales, and similar features, which may not be depicted due
<br />to scale".
<br />33. Amore specific commitment m the creation of topographic diversity on graded spoils, and an additional
<br />commitment to extensively roughen replaced soils on slopes steeper than 25%, was incorporated into permit
<br />text in Tab 22, page 12, in April 2003 via PR-3 (approved June 2003). The commitment language states that
<br />In the future, all bac~lled spoils will be graded to create irregular topographic undulations...
<br />In order to avoid possible future uncertainty regarding when these requirements took effect, please
<br />replace the phrase /n lhejuture, with Beginning June 2003.
<br />34. A number of existing haul roads are proposed for permanent retention, including road G, the MEHR, the
<br />segment of Road A west of the intersection with Road H, Road J, and Road K. Other haul road segments aze
<br />not proposed for permanent retention, including the abandoned segment of Road A east of the Road H
<br />intersection, and Road I. Roads to be retained as permanent are to be partially reclaimed (narrowed) for
<br />postmining use, while temporary roads are to be fully reclaimed. Approved reclamation schedule on Exhibit
<br />19-1 indicates that partial reclamation (width reduction grading) is [o be completed on Road G, MEHR, and
<br />lower Road A (west of Road H) by [he end of 2005. Based on the currently approved mine plan, the schedule
<br />for lower Road A and the MEHR may be out-dated, as it would appear that these roads would need to be used
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