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G94-082: PAR : S. Bu~vneier 2 B) In Tab 21 Table ]and Table 2 are not in agreement on topsoil replacement depth. Footnote No.2 on Table 1 states, "...Therefore, the average soil replacement thickness for all soil disturbance areas will be 1.6 feet " Whereas, footnote No.3 on Table 2 states, 'This soil will be replaced on the mine area and remaining facilities to a thickness of 1.8 feet:' Please bring these two tables into agreement. The Division has digitized the soil resources illustrated on Exhibit 9-1 in relation to Exhibit 20-1 "potential disturbance boundary". This exhibit demonstrates that SCC should have sufficient soil resource to replace the proposed 1.8' soil thickness on the mine disturbance area and 1.0' soil thickness on the facilities and haul road A and B corridor. 2) SCC is proposing to use extended reference areas. These are not defined as to location. Seneca does commit to managing these extended reference areas the same as the reclaimed area. The Division needs assurance that these extended reference areas will not be disturbed. SCC needs to provide a designation on a map of the location of the "extended" reference area. SCC needs also demonstrate that the reference areas represent the area to be disturbed as per Rule 4.15.7(3)(b). 3) A) The Division is in agreement with the concept of the concentrated shrub areas. The Division considers a woody plant density of 1000 stems per acre on the 5% of the reclaimed area that constitutes the shrub concentration areas, on the low side. To put this into perspective, this would impose a standard of 1 shrub every four square meters on only 20 acres of the 404 affected acres during the first permit term. The overall reclaimed area standard of 250 stems per acre translates to 1 shrub per every 17 square meters. Due to the fact that one of the proposed postmining land uses will be for wildlife habitat the Division questions whether the 1000 stems per acre within the clumped areas will be adequate for wildlife utilization. The Colorado Division of Wildlife has not yet responded to these density levels. Please have Seneca Coal Company propose a denser standard for the concentrated shrub plat areas, or provide additional information to justify this level of shrub density within the concentrated shrub areas. B) While the Division recognizes that Seneca Coal Company is proposing progressive attempts at re-establishing the woody species, we are also concerned about failure of these concentrated areas. If these concentrated shrub plots should fail Seneca Coal Company needs to be aware that they will need to attempt re- establish them. 4) Revegetation cover success standard: Seneca Coal Company has proposed to use an acreage weighted calculation of herbaceous vegetation cover in the reference areas