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• <br />• <br /> <br />January 24, 2002 <br />Page 3 of 3 Pages <br />During the first growing season, sampling is required to determine frequency by genera of seeded <br />and volunteer species. During the second and fourth season herbaceous cover and woody plant <br />density information is gathered. <br />The report contains the.results of sampling bf 1998 for frequency/density, and 1998 and 1996 <br />cover data and woody plant data for reclaimed areas in compliance of the requirements of the <br />'Permit. However,. the report includes a discrepancy. in dates. The operator is asked to reconcile <br />the discrepancy in the adequacy letter of January 24, 2002. <br />Final Topography <br />A current (flight date of October 2, 2000) description of topography was provided in the report <br />(Drawings, Exhibit 9, 2000 Annual Report and Exhibit ]0, Maps I and 2 of 2). Three cross- <br />sections of current topography were provided in the report. Cross-section 2-2' engages 2000 <br />reclamation in the vicinity o€ the East Pit. The backflling accomplished is in compliance with <br />the Permit, with actual surface elevations in close (0 to.10 feet) of approved post mining <br />topography. Cross-section 3-3' of the reporE (Exhibit 10) is cross-section D-D' of Map 19, <br />approved Post Mine Topo (last revised 5/30/01). The 2000 reclamation is of a portion of the <br />excess spoik West Pit Fill. This area was also backfilled to approved topography. No 2000 final <br />topography reclamation is claimed in the vicinity of the Section 16 Pit. <br />Aerial Photography <br />mining at the Section 16 Pit to south from north in lieu of the historic east to west, final <br />backfilling and grading was suspended due to the need for longer-term spoil storage. <br />Reclamation behind the west pit has not progressed off the excess spoil fill. <br />Aerial photographs of the mine were submitted in Exhibit 11 of the report. A review of these <br />photographs indicates that the mine is being operated in compliance with the Permit. <br />Reclamation of the East Pit lags the active pit by approximately (scaled from the photograph) <br />3400 feet (Photograph SS-3). An explanation by the permittee (Coal Inspection of March 8, <br />1998) is that the most northerly portions of East Pit un-reclaimed areas are to receive excess spoil <br />from the expansion of the West Pit to the east. The lag is considered to be within the approved <br />variance in the permit for contemporaneous reclamation. With the change in the direction of <br />