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<br /> <br />Memo to Erica Crosby <br />Yoast Mine, File No. C-94-082 <br />-2- <br /> <br />May 25, 1995 <br />77, a. Seneca Coal Company defines the extended reference area as 'al[ <br />undisturbed lands between the permi[ boundary and the life-of--mine <br />disturbance boundary for the first permit terns': The proposed <br />extended reference area meets the requirements for Rule 4.15.7(3). <br />Seneca Coal Company needs to diligently maintain boundary <br />markers for the approved disturbance area since the disturbance <br />azea boundary defines the area available for the extended reference <br />area. <br />b. Seneca Coal Company has provided demonstrations showing <br />comparability between the affected area vegetation communities and <br />the extended reference area. This comparison used a 95 percent <br />confidence interval which is in agreement with pre-mining <br />comparisons suggested in the Division's Guidelines for Land Use <br />and Vegetation Requirements, dated October 1988. Seneca's <br />response addresses the Division's request for demonstrating <br />comparability between the life-of-mine affected area and the <br />extended reference area. One note; Tab 22-1, page 1 contains a <br />typographical error. In the formula for the student's t test one of <br />the denominators, ri;, in the square root should be changed to n;. <br />78. Seneca Coal Company responded to the Division's concerns of density of <br />concentrated shrub areas by increasing the number of concentrated shrub <br />areas and increasing the number of acres to be occupied by the <br />concentrated shrub areas. The proposed number of concentrated shrub <br />areas has been increased from eight to fifteen, and twenty acres to twenty- <br />nine acres. Seneca Coal Company has proposed locating the shrub <br />concentration areas to establish travel corridors and breaking up large <br />extents of grassland dominated reclaimed areas, thus providing greater <br />"edge" for wildlife usage. <br />This increase in concentrated shrub areas is an increase from 5% to 7% of <br />the first permit term disturbance area. Seneca continues to propose a <br />woody stem density standard of 250 stems per acre throughout the <br />reclaimed area, with 1000 stems per acre standard applied to the <br />concentrated shrub areas. The Division commends the proposed increased <br />number of concentrated shrub areas, spatial diversity, and increased <br />acreage occupied by the concentrated shrub areas, but the Division <br />continues to question the overall proposed shrub density. <br />Seneca Coal Company contends that the Division is requiring "restoration <br />of moderate to high densities" of woody plant species. Review of the pre- <br />