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the area disturbed under the coal permit that will eventually be disturbed under the gravel permit, but the actual <br />disturbance under the gravel permit may not occur for several years. Would the vegetation ground cover erosion control <br />requirement of 4.15.10 apply for such areas? I didn't give a definitive answer in the meeting, but I was leaning toward yes, <br />the vegetation cover requirement would apply. 4.15.10(2) is pretty specific in stating that there is a cover requirement that <br />must be met prior to final bond release. Would the cover requirement have to be met for the entire disturbed area, or <br />could we apply some discretion, and require vegetative stabilization only for locations which would not be disturbed under <br />the gravel permit for some specified minimum time period (e.g. 1 year)9 <br />As you can see, there are a number of devilish details that we will need to be sure about before we get too far along in this <br />process. I stated at the meeting that I wuld not definitively answer all the questions at this time. I requested that, as an <br />initial step, United Companies should submit a draft gravel mining plan and schedule for the site, that would allow us to <br />identify the critical issues and address in more detail the specific requirements for release of the coal bond and termination <br />of the coal permit, under the "fast track" approach. They seemed amenable to this. Steve and I stressed that, up until the <br />point that the coal permit is terminated, compliance with alt components of the coal permit including sediment and drainage <br />controls would be required and would be the responsibility of the coal permittee. <br />Please give some consideration to this issue, and let me know your thoughts and concerns. You may want to peruse the <br />applicable rules, 3.02.3(2)(c), 4.15.10(2), 4.16.3, and applicable sections of 4.14. You mentioned when we last discussed <br />this matter that David thought there might be some "takings" issues we needed to be cognizant of. Would operational <br />delays associated with demonstration of adequate vegetative cover possibly come into play? <br />Thanks <br />