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Page 5 <br />Section 3.03.1 <br />The Division does not concur with the selection and use of the post-mining P factors <br />used in the calculation. The applicant has fixed the pre-mining factor, which is <br />acceptable. However, no adjustment of the post-mining P factor is warranted. The <br />practice of contour plowing and cultivation due to drill seeding is marginal at best. In <br />addition, since the calculation is an annual estimate, it is not appropriate to credit this <br />roughening component to lands that receive no management practice after the initial <br />seeding. The post-mining P factor should be equal to the pre-mining factor unless the <br />applicant has evidence that management practices were used on a recurrent basis <br />and/or any management practice employed at the time of seeding remains functional at <br />the time of Phase II sampling. <br />The applicant should revise parameter input based on the above comments and re- <br />submit Table 4. C factor information is presented below for the reclamation and <br />reference areas. <br />Mean Total Hydrologic Cover, 2006-2009 Phase II Vegetation Data <br />Year /Area Plant cover Litter <br />cover Total hydrologic cover <br />2006 Reclaim 43.4 44.3 87.7 <br />2006 MS 39.9 48.9 <br />2006 Sage 32.6 45.8 <br />2007 Reclaim 66.8 21.1 87.9 <br />2007 MS 56.3 33.6 <br />2007 Sae 57.2 29 E N <br />2008 Reclaim 71.5 22.2 93.7 <br />2008 MS 63 31.3 <br />2008 Sage 57.8 25.6 <br />2009 Reclaim 69.7 21.6 91.3 <br />2009 MS 61.3 33.2 <br />2009 Sage 48.3 37.2 <br /> Four Year Mean Total <br />Cover C factor <br />Reclaim mean 90.1 .007 <br />]Lean <br />2 .005 <br />mean <br />- .011 AN estimate of soil loss can be found below: <br /> <br />http://www.fishwild.vt.edu/haas/haas pdf/usle.pdf