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Mr. Mark s'. Loye -2- October 19, 1982 To show the location of moderately mobile equipment on the map would require revisions to the permit every six to mine months for the next 45 years. We believe that a description of the equipment and a statement that its location is kept as near as possible the mining face is sufficient. 3. We agree that the description of the topsoil removal process in Exhibit D is rather brief. This was done to avoid unnecessary redundancy with the more detailed description in Exhibit E. Actually, we consider topsoil removal to effectively be a reclamation operation. Where the topsoil salvage process fits in the mining/reclamation sequence is probably subject to debate. ;iowever, we feel that the description in Exhibit E is the one that should be most carefully studied and complied with. As indicated in Exhibit E, the topsoil removal and replacement process is a haulback method commonly used on coal strip mines. Ideally, the soil is simply respread over regraded land. However, the ability to implement this ideal situation is totally dependent upon timing. To acquire the best growth in the shortest period of time requires that the vegetation be planted within three weeks of soil redistribution, and prefer- ably even sooner. This places heavy constraints on soil stripping and redis- tribution. More often than not, the soil is simply stockpiled for a period because the time of stripping and redistribution is not compatible with the time of seeding. Experience on other mines has shown that the revegation success achieved by topsoiling and/or final grading just prior to seeding is much greater ti~an by using other methods and timings. Therefore, the topsoil stockpile and redistribution pattern will follow several hundred feet behind the mining and processing. In effect, the topsoiling sequence is dictated by the mining sequence and follows the mining out of phase by several hundred feet. Showing such a sequence on a map would be conceptually redundant. The locations of topsoil stockpiles will be shown on annual reports. The last annual report map showed the present locations of stockpiles, excepting those that have been removed through topsoil redistribution since the annual report was prepared. 4. Once again with regard to horizon separation, cve ask you to please refer to Exhibit E and the response to item 2 under Exhibit E in your letter of October 6, 1982. we did not feel that the mining plan was the appropriate place to address such operations as cve feel they are mote appropriately considered to be reclamation operations. Exhibit E 1. [ve agree that mulching is important to revegetation in dry areas. However, the definition of dry areas is ecologically relevant only with respect to the plant species growing there. If species are used that are resistant to drought and they thrive in what- is normally considered droughty conditions, then