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2014-04-03_REVISION - C1982057 (4)
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2014-04-03_REVISION - C1982057 (4)
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Last modified
8/24/2016 5:41:50 PM
Creation date
4/3/2014 1:28:03 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982057
IBM Index Class Name
Revision
Doc Date
4/3/2014
Doc Name
Adequacy Response No 1
From
Seneca Coal Company
To
DRMS
Type & Sequence
SL5
Email Name
JHB
DIH
Media Type
D
Archive
No
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2. The SL -4 Phase I bond release application was partially approved in January 2014. Stock <br />tanks T -5, T -18, T -20 and T -24 were approved as were the upper reaches of PM 2 -D. PM 4- <br />D was not approved and has been removed from the Phase II Sl -5 application including the <br />maps. <br />3. The exclusion areas noted above as still requiring removal total 4.7 acres. Additionally, 49.7 <br />acres was removed in the very southern block of the Phase II application area. The total <br />acreage removed from the original request is 54.4 for a new total Phase II request acreage of <br />805.1 acres <br />Revegetation Success <br />4. The correct 2009 Vegetation Monitoring Report was previously submitted to CDRMS in <br />2013. The Revegetation Success section in the SL -5 document has been revised. <br />5. The percentage contributions of the native pre -mine vegetation in the disturbance area have <br />been verified for the permit area. These are presented in the weight averaging discussion <br />associated with the revegetation success section in Tab 22 of the Seneca II -W permit. <br />Reevaluating percentage contributions of the native pre -mine vegetation for each block of <br />bond release (see page 45 of Tab 22) would be time consuming, unnecessarily complicated <br />and would mean very little, if an quantifiable difference in final success evaluations. For <br />larger blocks, the pre -mine vegetation types are reasonably well distributed over these larger <br />areas. Conversely, a smaller block may be concentrated in a pre -mine type location that as a <br />whole does not reflect the reclaimed area site potential or capability which as a function of <br />the mining and reclamation process creates more homogenous site characteristics. The best <br />example would be a pre -mine aspen site which has very high cover and productivity levels <br />based on site potential but that does not reflect the site potential of the average reclaimed site. <br />Knowledge gained from observation and monitoring both in the reclaimed areas and the ERA <br />over the last 14 years illustrates that the ERA, which covers approximately two thirds of the <br />mine permit area, is well representative of the pre -mine vegetation condition for all potential <br />reclamation blocks. SCC requests that the weighting approach and the cover success <br />
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