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standard presented in the 2009 vegetation study used for SL -5 be considered the appropriate <br />technical lcfpcmvdpjnonstration. <br />6. SCC agrees with the Division's comment that "the sampling conducted in each vegetation <br />type in the northern extended reference area is likely representative of the same vegetation <br />types found in the extended reference area in the South Extension Area ". During the course <br />of various baseline studies conducted on the Seneca II -W permit area, comparability of areas <br />to be affected by mining and undisturbed areas available for use in an ERA have been made. <br />7. The permit area is relatively small for a surface mine and encompasses roughly 5.5 square <br />miles over an approximate 4.5 mile north to south traverse. Elevations are fairly consistent <br />from north to south with the elevations in the southern portion slightly higher. These <br />undisturbed areas represent similar ranges of soils, elevations, aspects, slopes, and phases of <br />the representative vegetation communities in the affected areas. Because of the similarity of <br />vegetation types and site characteristics over the entire Seneca II -W permit area, large areas <br />of the undisturbed primary vegetation types within the permit area can be quite <br />representative of the entire permit area. The ERA sampled over the last 14 years <br />encompasses the approximate northern two thirds of the permit area and is very <br />representative of the entire permit area. Over these last 14 years, reclamation monitoring <br />data has been collected and compared to weight averaged data collected from the native <br />vegetation types of this ERA during the same period. This is an excellent record of <br />vegetation response to varying climatic conditions over time and supports using the northern <br />two thirds ERA of the permit area for success evaluations. <br />This ERA maximizes the use of the extensive undisturbed lands within this area for a valid <br />comparison of native vegetation types to reclaimed lands. The total maximum disturbance <br />area is illustrated on Exhibit 22 -1. As can be seen from review of this exhibit, considerable <br />undisturbed areas remain in this area and all pre -mine vegetation communities are <br />represented in these undisturbed areas (compare Exhibit 10 -1 with Exhibit 22 -1). The extent <br />of these undisturbed vegetation communities and the proximity to all reclaimed areas provide <br />good comparison of pre -mine site and vegetation conditions. SCC has surface control of all <br />lands in this extended reference area region. This has allowed SCC to manage the ERA in <br />