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INTEROFFICE MEMORANDUM <br />TO: DAVID BERRY <br />FROM: JANET BINNS <br />SUBJECT: SOUTHFIELD MINE TR39, ADDITIONAL INFORMATION SUBMITTED BY EFCI ON 11/5/2013 <br />AND NOVEMBER 12, 2013 <br />DATE: 11/15/2013 <br />CC: DAN HERNANDE'L, ROB 'I.UBER <br />Good afternoon David, <br />I have reviewed the additional Map 16, and Map 1 "Southfield Mine Reclamation Map" submitted by <br />EFCI on 11/12/2013. EFCI did not correct the text items that I previously identified in my memo <br />to you, dated 11/6/2013. My original concerns are repeated in italics in this memo: <br />On 111512013, EFCI submitted additional information to the Division to address the Division's letter <br />requesting clarification, dated October 18, 2013. <br />DBMS had asked EFCI to clarify how EFCI proposed to combine the vegetation sample data for the <br />Proposed Reference Area and Plot B reference area as proposed in EFCI s revised page 2.04.10 -5, <br />submitted October 7, 2013. <br />The Division requested that EFCI s clarification of how EFCI would combine the vegetative data from the <br />two woodland reference area would be statisticaly valid, would be in agreement with statistical approaches <br />found in Rule 4.15.11, and directed EFCI to the Divisions Guideline Regarding Selected Coal Mine Bond <br />Release Issues, April 18, 1995, for an example of an acceptable approach. Example 3, on page 26 -27, of <br />the April 18, 1995 Guideline contains an example that was appropriate to the Southfield situation. <br />Instead of simply defining how the reference area data would be combined, EFCI submitted an approach that <br />defines the ratios of the reclaimed communities that would be applied in the acreage weighted approach. The <br />November 2013 revised pages 2.04.10 -5 and 2.04.10 -5a, do hep define how EFCI will apply the acreage <br />weighted bond release block approach. <br />Item No. 1: The November 2013 revie ed pages 2.04.10 -5 and 2.04.10 -5a, do not address the Divisions question to <br />define how the data from reference areas will be combined. Example 3 in the April 18, 1995 Guideline <br />applies to an Acreage weighted reference area comparison /Acreage weighting in Bond Release Block. This <br />example is applicable to the Southfield reclamation success comparison. <br />As submitted, EFCI doesn't completely resolve the Divisions concern. In order to answer the question <br />EFCI needs to provide the respective ratios of the reference areas. <br />Example. Grassland reference area (Plot A) =X acres <br />Ponderosa /pinyon /Juniper reference area (Plot B) = Y acres <br />