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Mr. Michael G. Leidich -3- June 20, 1984 Exhibit J 7. Rule 2.12(10) requires that the on-site vegetation information for a proposed permit area for a 112 application be quantitative in terms of estimates of cover and height for the principal species in each lifeform. It further requires the relationship between vegetation and soils to be given and that production estimates be made for areas to be reclaimed for range or agriculture. The relationship between existin vegetation and topography should also be shown. Please review Ruie 2.1210) and submit approximate vegetation information. The Soil Conservation Service may be of some help in this regard. Exhibit L 1. In general, an analysis of your proposed reclamation costs, given the plan outlined, shows them to be an underestimate. Furthermore, some parts of the cost estimates are not clearly defined enough to be useful. Perhaps a more detailed phasing plan for the two permit areas might be helpful in this regard. In general, however, the costs involved will probably be higher than you have illustrated. I will elaborate further, below. 2. Your cost figure for the grass seed mix seems low. Our research indicates that your reclamation seeding mixture would cost at least $38/acre. (3. Costs for mulch are typically at least $100/ton. Thus the appropriate (figure for your plan would be $200/acre. 4. Backfilling would not be able to be done by the state for $.38/cu. yd., and respreading topsoil would cost more than $.59/cu. yd. at current rates. A more acceptable (though still very conservative) figure would be $.60/c u. yd. for backfilling and $1.00/c u. yd. for topsoiling. 5. What is the source of your costs of $110/acre for revegetation operations? Given necessary multiple passes with equipment for the necessary operations, these costs are usually considerably higher. 6. The amounts of material to be backfilled is not justified and seems much too low. Subtracting 5 acres of roadways, 20,000 cu. yd. of material backfilled over 30 acres gives only 667 cubic yards per acre or about 5 inches depth of backfilling per acre. Given the nature of the clay deposit, this seems like an underestimate. Please justify or modify your figure for backfilling volume. 7. Given a depth of topsoil of 10" (the average of your 8"-12" replacement depth), the amount of topsoil to be replaced is much too low to reclaim the 30 acres requiring such treatment. This amount of topsoil, in fact, would produce a replacement depth of only about 2.5" over 30 acres. Again, please justify or modify your figure for topsoil volume.