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Rule 4.06.5 14. On page 2.05.4-17 and page 4.06-6, EFCI commits to sampling and completing laboratory analyses on the upper four feet of replaced soil and underlying material prior to seeding. A good discussion of their sampling plan is on page 2.05.4-17. Results of all soil sampling must be provided to the Division prior to final seeding per Rule 4.06.5. A commitment to submit the results to us prior to seeding is not included in the narrative, and it should be added. Rale 4.10 15. Shortly after the new refuse pile expansion was approved the mine stopped operating. Consequently, the new portion of the pile was not completed as proposed. Please provide a plan to the Division that addresses how the refuse pile will be completed and what steps will be used to insure its long-term stability and ensure that it will blend in to the existing topography. Please provide a final certification for the refuse pile after compaction/grading have been completed. Please update the post-mining topography and post-mining cross-section maps as necessary. Rule 4.15 16. EFCI has two proposed seed mixes. Table 331ists a seed mix for temporary seeding and also a list for permanent seeding. Given that EFCI is conducting permanent reclamation, there will be no longer be a need for the temporary mix. Please confirm that this is a cosect assumption. The permanent seed mix contains two introduced species that the DMG strongly discourages. They are introduced species that are not as beneficial for the post mining land use as compazable native species. Specifically, Crested wheatgrass and Intermediate wheatgrass should be removed from the mix. These are both cool season gasses that could be replaced with: Indian ricegrass (Achnathenun hymenoides), Needle and thread grass (Stipa comata), Muttongrass (Poa fendleriana), Beazdless bluebunch wheatgrass (Pseudorogeneria spicata ssp. inermis), or another appropriate native grass. The discussions on pages 2.05.4-22R and 4.15-2R, Use of Introduced Species, should be revised accordingly with the revised seed mix. The seeding rate that EFCI has proposed of 6.55 Ibs/acre seems appropriate. However, DMG also looks at the PLS/ftZ. Generally, DMG recommends approximately 20 PLS/ ftZ and EFCI is proposing 49 PLS/ ft2. EFCI may want to reduce the seeding rate to reduce the number of seeds per squaze foot 17. Section 2.05.4, page 2.05.4-26, discusses the methods for determining the success of revegetation efforts, based upon comparisons of vegetative cover, herbaceous production and woody plant density between reclaimed areas and approved reference areas. The methods discussed in this section are in compliance with the requirements of Rule 4.15.8. On page 4.15-SR EFCI refers to azeas previously disturbed by mining where the reclamation . success will be evaluated on the basis of effective erosion control and comparisons of resulting ground cover with previously mined areas having similar soil/suitable material thickness and characteristics. This discussion of reclamation success is not consistent with the discussion in Section 2.05.4.