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Mr. Roy Karo <br />June 5, 2014 <br />Page 2 <br />3. The Division asked SCC to recalculate the acreage of the exclusion areas discussed in items 1 and <br />2 above. <br />SCC response: The areas excluded by items No. 1 & 2 account for 4.7 acres. The total area that <br />will be removed from the original SL5 application totals 54.4 acres. SCC requests total Phase II <br />bond release of 805.1 acres. SCC's response is acceptable. <br />4. SCC initially submitted an incorrect revegetation monitoring report for Attachment E. <br />SCC submitted the correct revegetation monitoring report on August 2, 2013. The <br />Revegetation Success section of the SL5 bond release application needs to be revised <br />based on the correct revegetation monitoring report results and as a result of SCC <br />response to this adequacy review. <br />SCC response: The Revegetation Success section in the SL5 application has been <br />revised. The correct data set was submitted April 5, 2010. SCC provided revised 2009 <br />vegetation sampling summary on April 3, 2014, with the 2005 -11 excluded are transect <br />that fell within the removed. Statistical sample adequacy was still achieved with this <br />transect data removed. SCC submitted a corrected Table 1, Table 2, Table 9, Table 10, <br />and Table 11. This response is adequate. <br />5. In the September 4, 2013 Par, the Division requested that SCC recalculate the <br />acreage weighted ratio of the bond release block. <br />SCC's response was recalculation of the acreage percentages for each Bond Release Block <br />(BRB) is unnecessary and unwarranted for large blocks that include several community types <br />prior to disturbance. Recalculating the acreage weighting percentage for each bond release <br />application would make little difference in the weighted standard. This recalculation may be <br />appropriate for small parcels that fall within only one or two of the pre- mining communities, but <br />not necessary for a larger block like the SL5 BRB. <br />DRMS concurs. This response is acceptable. The Division finds SCC applied the acreage <br />weighted values consistently with the pre- mining ratios shown on Tab 22, page 45, in the Seneca <br />II West permit. <br />6. After initial review, the Division noted that SCC located in the southern extension extended <br />reference area had not been sampled. The Division believes the sampling conducted in each <br />vegetation type in the northern extended reference area is likely representative of the same <br />vegetation types found in the extended reference area in the South Extension Area. However, <br />SCC should be aware of this permit requirement for future bond release applications, and ensure <br />that the Southern extended reference area is sampled concurrently with reclaimed parcels located <br />in the southern expansion area. <br />SCC response: Concurs with Division's statement that vegetation types in the northern ERA are <br />likely representative of the same vegetation types fund in the Southern ERA. DRMS did not <br />require any action at this time, but more of a notice for future sampling. This response is <br />acceptable. <br />