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olQ?vya's most recent submittal daes not provide the necessary details and <br />commitments requested. In their cover letter and revised narrative, the operator <br />indicates that they mould track sail replacement volumes, but not replacement <br />depthlthickness, regarding planned variable thickness soil replaceinent? they <br />refer to a near "profile description diagram" on amended page 2,45.4-46. The <br />referenced diagram is a ge?e?alized cross-section of a hypothetical reclaimed <br />?vate?shed, from ndgeline to ndgeline, showing 4 to ? inch soil thickness on <br />ridges and upper slopes, ? inch thickness to "a much as needed for topsail <br />balance" an lower half of slopes, and 4 to " adj scent to the channel, In the <br />arriended text, the diagram is described as "a visual representation of the general <br />goal..." ? the cover letter, the operator indicates that "deviations from the spirit <br />of the diagrani gill be discussed with the Division prior to cainpletion of topsail <br />laydon actlvities in ? given reclamation Unit, .." A.rnended narrative regarding <br />topsoil replacement refers to "average or variable replacement depth foXloing the <br />general rule ofthin topsoil ?4-$}inches on ridge tops to gradually thicker topsoil <br />moving down the slopes, . ," <br />The Division does not consider the amended plan to be adequate, a it does riot <br />provide the level of detail ar commitment necessary to demonstrate that topsail <br />would be redistributed to achieve "an appraxirnate uniform, stable thickness <br />consistent with approved pastmining land uses, contours, surface mater drainage <br />systems and requirements of the vegetation proposed to be established" as <br />required by yule 4.4?.?4??}?a}. The Division daes not interpret the regulation <br />language to require replacement of a single, uniform thickness across the entirety <br />of a reclaimed area, but daes interpret the language to require replacement of <br />defined approximate uniform thickness within delineated portions of a reclaimed <br />area. <br />Far the post-20QS portions ofthe anginal permit area, the Division mould accept a <br />variable replacement plan incorporating narrative and mapping commitnaeuts <br />adequate to ensure replacement of ? significant acreage of at least t?va sail <br />replacement zones, as follov?s: <br />a "thin soil" zone, with a Q to 8 inch replacement range and a 4 inch <br />minimum average thickness} and; <br />a "thick sail" Zane, with an S to 1 ? inch replacement range and a 1 a Inch <br />minlrXiunl average thlckness. <br />For the youth Taylor reclamation unit, the Divisions would accept a variable <br />replacement plain incorporating narrative and mapping commitments adequate to <br />ensure replacement of a significant acreage of at least three sail replacement <br />zones, as follows: <br />a "thin soil" zone, with a ? to 8 inch replacement range and a 4 inch <br />minimum average thickness; <br />