as having the following minimum characteristics:

1.

2.

3.

Adequate moisture supply (suggested:
monthly supply at least equal to po-
tential evapotranspiration during the
growing season in eight of ten years)

desirable soil temperature (suggested:
mean annual temperature of 32°F. or

greater, and mean summer temperature of
47°F. or greater, at a depth of 20 inches)

a growing season of sufficient length to
produce a commercial crop

4.

acceptable water table (suggested:
water table that can be maintained below
1.5 feet during the growing season)

a

5.

6.

7.

8.

9.

10.

appropriate levels of pH and conductivity
(suggested: pH between 4.5 and 8.4)

limited damage by flooding (suggested;
crop damage limited to no more than two
years in five)

low coarse fragment content (suggested:
less than 10% coarse fragments greater
than three inches in the surface layer)

low erodability (suggested: a product of K [erodability factor] x percent of slope of less than 1.5)

a contiguous area of sufficient size to
allow economical operations (suggested:
160 acres)

permeability (suggested: at least 0.02 inches per hour within 20 inches of the surface)

Second, Section 510 (b) (4) and Section 522 (a) (6) may be interpreted as conflicting on the question of whether substantial legal and financial commitments in relation to a permit as opposed to actual mining operations will insulate land from designation as unsuitable for mining. We suggest

that Section 510 (b) (4) of H.R.2 be revised to read as

follows:

(4) the area proposed to be mined

is not included within an area designated
unsuitable for surface coal mining pursuant
to section 522 of this Act or is not within
an area under study for such designation in
an administrative proceeding commenced pur-
suant to section 522 (a) (4) (D) or section
522 (c) (unless in such an area as to which
an administrative proceeding has commenced
pursuant to section 522 (a) (4) (D) of this
Act, the operator making the permit applica-
tion demonstrates that by reason of the pro-
visions of section 522 (a) (6) the remaining
provisions of section 522 are not applicable
to the operation for which he is applying for
a permit;)

Third, the procedures for securing the designation of lands as unsuitable for surface mining do not become ef

fective until after a state program is certified under Section 503 or a federal program is imposed under Section 504. In the case of the implementation of a federal program under Section 504, as much as 42 months could elapse before any petitions to designate land as unsuitable for mining could be filed. We believe that such delay could operate to frustrate the operation of one of the most important provisions of the legislation. There should be a method of making a preliminary administrative determination of lands that are unsuitable for mining. We believe that prime farmland should be designated on a preliminary basis by the U.S. Soil Conservation Service in cooperation with state soil agencies, based upon existing soils data. Such preliminary designation should be made within six months of the

effective date of the Act and a moratorium should be imposed on mining such lands until 180 days after a state or federal program becomes effective or the preliminary determination is rescinded in an appeal under Section 522 (c) of the bill. Our nation needs both its energy resources and

its food production resources. The recovery of sources of energy should not interfere with the production of food, even temporarily, unless it is plainly necessary. No such necessity presently exists. In Illinois, for example, the

recoverable reserves of coal that can be deep mined are ap

proximately nine times the reserves that are recoverable only. by strip mining.* Even if all of the coal that can be recovered by strip mining underlies prime farmland, which it does not, we believe that it should be the policy of this country to protect its agricultural land from the catastrophic disruption inherent in strip mining until the day arrives, if it ever does, when such coal reserves must be recovered.

We have only recently come to understand that we live in a fragile environment that is easily damaged, sometimes beyond restoration or reclamation. The late Arnold Toynbee, speaking of the biosphere, which he called the "film of dry land, water, and air enveloping the globe

*

Illinois Geological Survey, report in progress, as supplied by Jack Simon, Urbana, Illinois, March, 1977

of our planet earth", said

It is the sole present habitat--and,
as far as we can foresee today, also
the sole habitat that will ever be
accessible--for all the species of
living beings, including mankind, that
are known to us.

The biosphere is rigidly limited in its
volume, and therefore contains only a
limited stock of those resources on
which the various species of living
beings have to draw in order to main-
tain themselves. Some of these re-
sources are renewable; others are ir-
replaceable. Any species that over-
draws on its renewable resources or
exhausts its irreplaceable resources
condemns itself to extinction.*

At this time, no one can say with reasonable

assurance that our most productive agricultural land is a renewable resource that can be restored after strip It may well be irreplaceable. For this reason,

mining.

we support H.R.2 because it will provide protection for our resources of prime agricultural land.

Toynbee, Arnold, Mankind and Mother Earth,
Oxford University Press, 1976, page 5