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minor type (in terms of areal extent). The proposed revegetation plan for this mesic drainage <br />type should also be kept in mind when considering revegetation success criteria. <br />In March 1985, the Division issued Peabody Coal Company a set of adequacy comments based <br />on the review of the Seneca II-W permit application. Included was a comment regazding the <br />then proposed two-acre reference azeas and their comparability to the permit area. In May <br />1985, as part of a Peabody response package, the extended reference area approach was <br />proposed to alleviate the concerns of the Division. The approach and response were approved <br />as part of the August 5, 1985 Decision and Findings of Compliance document for [he Seneca <br />II-W Mine permit. The Seneca II-W permit was signed on December 31, 1985. <br />In response to Peabody's Permit Revision 1 (PR 1) to the Seneca II-W permit, the Division <br />issued a Preliminary Adequary Review letter on March 11, 1991, which, in pazt, required <br />documentation of the comparability of the extended reference area to the mine affected area. <br />Peabody responded to this requirement as part of an April 26, 1991 response package to the <br />Division's Adequacy Review letter The response, prepared as a demonstration of extended <br />reference azea and mine affect area comparability, was approved by the Division in the June 3, <br />1991 second adequacy review letter to Peabody. Appendix 22-2 contains the information, • <br />which supports the above-referenced demonstration. Tab 10, Vegetation, and in particular, <br />Appendix 10-9, contains the data, which were used in the comparability assessment for the II- <br />W affected and extended reference azeas. <br />In similar fashion, the II-W South Extension Area will use the extended reference azea (ERA) <br />approach to assess revegetation success for the cover and production performance standards. <br />However, for the South Extension Area, the applicable extended reference azea will be those <br />portions of the South Extension Area permit azea not to be affected by mining and sampled as <br />an ERA during baseline vegetation studies (see Tab 10). In other words, upland reclamation of <br />other areas will be judged either by the II-W ERA or by specific baseline datasets as detailed <br />elsewhere. Comparability of the II-W South Extension Area affected azeas and the ERA for <br />each of the six vegetation types is assessed in Tab 10. <br />The extended reference area approach maximizes the use of extensive undisturbed lands within <br />the permit azea foz a more valid compazison of native vegetation to reclaimed lands. Mining of <br />recoverable coal seams is more or less centered in the southern and northern portions of the • <br />permit area. Additional mine-related disturbances Eor facilities, haul roads, sediment ponds, <br />topsoil stockpiles, and all grading disturbance are located adjacent to these northern and <br />TR-50 <br />