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i <br />lift, 1 foot replacement thickness. However, for Block "A" areas, the 22 inch <br />average thickness is still significantly less than should be available for <br />replacement, based on documentation provided in the Soils Resource Information <br />section of the application, and the Soil Baseline Map (Map 2.04.9-1). <br />Information has not been presented to demonstrate that salvage of upper lift <br />soil only, and replacement directly on graded spoils with no subsoil <br />replacement, will be sufficient to restore the productivity of the irrigated <br />agricultural soil types. Unless such demonstration is provided, please revise <br />the pertinent narrative to specify two lift salvage and replacement for the <br />irrigated agricultural soil types. In addition, please revise the block specific <br />soil lift average thickness specifications of Map 2.05.4-4, and related <br />narrative, as appropriate. <br />4. There is an internal inconsistency on Map 2.05.4-4, regarding the replacement <br />method for Block D. The map key section indicates that a two lift replacement <br />procedure would be used for Block D, whereas other sections of the map indicate <br />that a 1 lift soil replacement would apply to Block D. <br />Please ensure that this discrepancy is corrected on the amended Map 2.05.- <br />4. <br />5. The soil replacement procedure for the 1999 (PR-5) expansion area is briefly <br />summarized in a paragraph at the top of page 2.05.4(2)(d)-21. Statements in the <br />paragraph imply that all Lift 1 topsoil will be salvaged ahead of active mining and <br />redistributed as evenly as possible over freshly graded backfill, and that Lift 1 and <br />Lift 2 laydown thicknesses will vary from mining cut to mining cut. The <br />paragraph further states that topsoil pickup areas can be identified on Map 2.05.4- <br />4... <br />Language in this section is confusing; in a 2 lift topsoiling operation, Lift 1 soil <br />would not be replaced directly on graded backfill, but rather would be replaced <br />over Lift 2 soil. Also, the final sentence in the paragraph references Map 2.05.4-4 <br />as depicting "topsoil pickup areas". This reference is incorrect, since Map 2.05.4- <br />4 depicts topsoil replacement areas. Please amend the text as warranted to <br />clarify the salvage and replacement sequence and to correct the erroneous <br />reference. <br />6. The variable laydown thicknesses associated with individual pit cuts as described <br />on page 2.05.4(2)(d)-21, do not comply with Rule 4.06.4(2)(a), which requires <br />that topsoil redistribution achieve an approximate uniform thickness consistent <br />with the approved postmining land use and requirements of the vegetation. <br />Please amend the narrative to demonstrate compliance with 4.06.4(2)(a). A <br />practicable approach may be to specify a reasonable replacement thickness <br />range as well as average thickness, based on information from the baseline <br />study, for each soil lift within each designated replacement block. <br />7