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to the Division's Adequacy Review letter. The response, prepared as a demonstration of <br />extended reference area and mine affect area comparability, was approved by the Division in <br />the June 3, 1991 second adequacy review letter to Peabody. Appendix 22-2 contains the <br />information which supports the above-referenced demonstration. Tab 10, Vegetation, and in <br />particular, Appendix 10-9, contains the data which were used in the comparability assessment <br />for the II-W affected and extended reference areas. <br />In similar fashion, the II-W South Extension Area will use the extended reference area (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 area will be that <br />portion of the South Extension Area permit area not to be affected by mining and sampled as <br />an ERA during baseline vegetation studies Isee Tab 101. 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 areas 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 area for a more valid comparison 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 for facilities, haul roads, sediment ponds, <br />topsoil stockpiles, and all grading disturbance are located adjacent to these northern and <br />southern areas. The total maximum disturbance area is illustrated on Exhibits 22-1 and 22-1A. <br />As can be seen from review of this exhibit, considerable undisturbed areas will remain after <br />mining-related disturbances. These undisturbed areas represent similar ranges of soils, <br />elevations, aspects, slopes, and phases of the representative vegetation communities in the <br />affected areas. All premine vegetation communities are represented in these undisturbed areas <br />loverlay Exhibit 10-1 with 22-11. The extent of these undisturbed vegetation communities and <br />the close proximity to the reclaimed areas provide the best comparison to premine site and <br />vegetation conditions possible. Peabody has surface control of all lands to be included in the <br />extended reference area. This will allow Peabody to manage the reference areas in accordance <br />with the approved postmining land use. It will also facilitate similar management for both the <br />reference and revegetated areas for any bond release evaluations during the last two years of <br />the liability period. <br />The following details the comparisons to be made between reference area information and the <br />various revegetation communities to be returned on the postmining landscape. These <br />comparisons reflect reclamation experience and revegetation monitoring data from the nearby <br />Seneca 11 Mine. The comparisons attempt to provide realistic and achievable standards that <br />38 Revised 1/99 <br />