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According to the CDMG's definitions, the change in disturbed area associated with PR-05 is <br />accurate and does not include the undisturbed "minimal dist-urbance" areas. The acreages <br />given below reflect the shaded areas as shown on Eyjubit 12-2 and the revegetation map, <br />Exhibit 22-1, Postmining Vegetation. The areas are conservatively overestimated for the <br />reasons stated above. <br />Mine Area: <br />Acres Permitted for Disturbance 1,334.5 ac <br />Acres Actually Disturbed 1,139.9 ac <br />Total Disturbed Area: <br />Acres Permitted for Disturbance 1,534.5 ac <br />Acres Actually Disturbed 1,236.5 ac <br />Backfilling and Grading <br />Rough grading will be performed with bulldozers, scrapers, graders and, occasionally the <br />dragline. Bulldozers and scrapers are used for final grading. SCC does not plan to remove <br />any necessary reclamation equipment from the area of operation until final reclamation is <br />completed. Typically, the process of grading begins with bulldozers building roadways into <br />the ungraded spoil. Once sufficient access into the spoil is provided, dozers or scrapers move <br />the spoil material in the direction and the amounts required to achieve the desired land form. <br />The movement of spoil material is generally downslope, due to economic and safety <br />considerations. Completion of rough backfilling and grading will be attempted within 180 <br />days following coal removal unless specific variances are applicable. Backfilled materials <br />shall be placed to minimize adverse effects on ground water, minimize off- site effects, and to <br />support the approved postm- ining: land use. The mine site will require a variance from <br />contemporaneous reclamation for specific areas and situations as described in Tab 19. <br />SCC's experience has shown that grading two spoil ridges simultaneously produces more <br />desirable reclamation results than grading one spoil edge at a time. This is because the <br />creation of graded slopes is primarily dependent upon the ability to perform "area grading" <br />versus grading one spoil ridge. Because of many variables encountered in the overburden <br />removal process, it is very difficult to predict the exact, final configuration of the spoil. <br />Thus, the final planning for reclamation grading must be performed after the <br />PR-06 2 Revised 07/11 <br />