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Page 2 of 2 <br />October 18, 2013 <br />The Division requests additional detail of how the data from the two woodland reference areas <br />would be combined. The acreage of the two woodland reference area is unequal. <br />Please provide sample methodology and data compilation that meets Rule 4.15.11. Please <br />assure that data compilation methods are statistically valid. EFCI may wish to refer to <br />the Division's Guideline Regarding Selected Coal Mine Bond Release Issues, April 18, <br />1995, for an example of combining data from more than one reference area. It is <br />suggested that the revised page can be edited to clarify that an area - weighted average will <br />be utilized. <br />2. Revised Page 2.04.10-5 (amended Oct, 2013) doesn't fit into the currently approved text <br />in the permit. Please assure that the text flows from previously approved pages to the <br />revised pages. Please make sure that pertinent information previously approved is not <br />inadvertently removed. <br />3. The revised page 2.04.10 -5 (amended Oct, 2013) refers to Map 16 for location of the <br />proposed Pinyon- Juniper reference area. Map 16 previously submitted, May 31, 2011 as <br />part of the TR39 application package was unapprovable as submitted. Information <br />depicting the pre- mining vegetation types was extremely faint, rendering the map <br />unacceptable. Please remove this reference. Please refer to the Exhibit 27, figures that <br />were previously included in the Division's proposed decision form. <br />Z ry <br />Director, Coal Regulatory Program <br />