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<br />letters are also included. These comments and consent forms <br />will be provided to the Division by March 15, 1995. <br />76. As stated in Response 75, all landowner and local government <br />agency comments will be provided by March 15, 1995 and <br />included in Appendix 22-2, Tab 22. <br />77a. Pages 36, 37, and 38 of Tab 22, Revegetation Plan, discuss the <br />extended reference area approach which will be used for <br />revegetation success evaluations. Page 37 has been modified <br />to state the extended reference area includes all undisturbed <br />lands between the permit boundary and the disturbance boundary <br />(first permit term and life-of-mine). Exhibit 22-1, Sheet 2 <br />of 2, has been modified with a statement similar to the text <br />in Tab 22. The area between the projected disturbance line <br />(dashed) and the permit boundary are lands available for the <br />extended reference area. <br />The projected disturbance boundary has been conservatively set <br />to ensure an estimate of maximum potential disturbance. At <br />this time, it is difficult to guarantee no disturbance will <br />occur in any portion of the extended reference area. However, <br />there are no mineable coal reserves in these areas and the <br />anticipated road system and facility locations are known. Any <br />disturbances which may occur will be minor and not extensive. <br />• The extended reference area approach has been developed, in <br />part, to absorb minor disturbances without affecting the <br />integrity of the reference area. <br />The minimum acreage estimates for the major types to be used <br />in the success evaluations were also determined on a <br />conservative level and considered the potential for some <br />additional disturbance. Even though greater acreages occur <br />for these types, the acreages presented on Page 37 of Tab 22 <br />represent the minimum which will be available. These <br />substantial type acreages within the reference area <br />representing the range of site conditions, will facilitate a <br />significant improvement over the previous control or reference <br />area approaches. SCC has surface control of all lands within <br />the revised permit boundary. <br />77b. As discussed in Tab 22 and in Part a of this response, the <br />extended reference area is the best approach for developing <br />comparison data which is representative of the areas to be <br />disturbed. Through valid sampling of the permit area <br />community types, it is assumed these types are representative <br />of the true population. Therefore, the population must also <br />be represented in a subunit (i.e., affected area or reference <br />area) of these community types, provided the size of the <br />subunits are large enough to reflect the variation within the <br />population and are located in proximity to each other. <br />• The demonstration of reference area and affected area <br />19 <br />