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<br />Tab 17 <br />59. CDMG is still reviewing <br />Tab 21 <br /> <br />72. Seneca's response is suitable. During the first permit term Seneca Coal Company <br />has stated that they will replace topsoil upon 242.6 acres to an average thickness oi<~. <br />1.8 feet. Seneca has also committed to replacing an average thickness of 1.1 feet of "1• <br />topsoil along haul roads A and B and the facilities area. ~ - <br />Life-of-mine topsoil replacement depths will average 1.6 feet in thickness. Since 1.6 <br />feet represents an average over the entire mine area, while the first permit term <br />reclaimed area will receive a 1.8 average topsoil replacement thickness, Seneca will <br />need to provide more detail on proposed topsoil replacement thicknesses prior to the <br />second permit term. <br />Seneca added a minimum topsoil replacement thickness commitment on Tab 21 page <br />23. This commitment states that a minimum thickness of 1.0 feet in the mine area <br />and a minimum thickness of 0.5 feet will be replaced along the Haul Roads A and <br />B. While the Division recognizes that a degree of variability is inherent in <br />reclamation activities, this variability is in the magnitude of 50 percent of the average <br />depths. This variability seems excessive. The Division feels that a commitment <br />should not deviate to such extreme from the proposed average. <br />Tab 22 <br />73. Not all landowner consent forms have been received. At this time Haul Roads A <br />and B cannot be approved to remain as permanent. <br />77. a. Seneca Coal Company defines the extended reference area as "all undisturbed <br />lands between the permit boundary and the life-of--mine disturbance boundary for <br />the fast permit term': The proposed extended reference area meets the <br />requirements for Rule 4.15.7(3). Seneca Coal Company needs to diligently <br />maintain boundary markers for the approved disturbance area since the <br />disturbance area boundary defines the area available for the extended <br />reference area. <br />b. Seneca Coal Company has provided demonstrations showing comparability <br />between the affected area vegetation communities and the extended reference <br />area. This comparison used a 95 percent confidence interval which is in <br />agreement with pre-mining comparisons suggested in the Division's Guidelines <br />for Land Use and Vegetation Requirements, dated October 1988. Seneca's <br />response addresses the Division's request for demonstrating comparability <br />between the life-of-mine affected area and the extended reference area. One <br />note; Tab 22-1, page 1 contains a typographical error. In the formula for the <br />