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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 t7ivision" iri <br />,the June 3, 1991 second adequacy review letter to Peabntly. .Appendix •22-2•contains the. <br />informatioir~which supports the above•reterenced demonstration. Tab 10; Vegetation, and in <br />' ~ particular, Appendix 10-9, contains the ~dats which were used in the comparabitity'assessmert[, <br />for'the II-W of}acted and extended reference areas. , ~ - <br />Im similar fashion, the 11-W South Extension Area "will use the extended reference area (ERAI <br />approach to assess revegetatiorr success for'the cover"and' production performance standards'. <br />However, for the South Extension Aiea, the applicable, extended reference area will be that <br />- portion of. the South Extension Area permit area not to be~aftected try mining and sampled as <br />an-ERA during baseline vegetation,studies (see Tab 101. ,In other words, upland reclaritation of <br />"other areas wil! be judged either. by the 11-W ERA or by specific baseline~datasets as detailed <br />' ~ elsewheie: Comparability of~the II-W South Extension Area affected areas grid the~ERA for <br />' each of the six vegetation typos is assessed in Tab~tO. <br />.. northernand southern areas.' The total maximum disturbance area is illustrated on.Exhibits <br />22-1 "and 22-tA. ' As can. be seen-from review of,this exhibit,' considerable undisturbed. areas <br />' will remain after mining-related disturbances: These undisturbed areas represent similar ranges <br />of soils, elevations, aspects, slopes, end phases o?'the representative .vegetation~.cammunities" <br />'jn~ the. affected areas. All premine vegetation communities .are represented in. these <br />undisturbed areas {overlay Exhibit 10-1 with. 22-11.' The extent~of these undisturbed <br />vegetation communities and ~ the close ,proximity to•the reclaimed, areas -provide the best <br />,'comparisontoprbmine site and vegetation conditionspossible~ Peabody has surface control <br />. of all lands to. 6e included in the extended reference area. This. will allow Peabody to• manage <br />. ~ .the reference areas in accordance.witMthe approved postmining land use. It will also facilitate <br />similar management ?or both the reference and revegetated areas' for. env bond release <br />- - ~~The extendedreference area. approach maximizes ihe~use•of extensive•undisturbed.lands <br />within the perrrtit~ area for a more Jalid'~comparison~af native vegetation to reclaimed lands. <br />Mining .of recoverable coat seams is •more .or~less centered.in the southern. and. northern <br />- portions bf the, permit area. Additional mine-related disturbances for facilities, haul roads, <br />sediment ponds, topsoil stockpiles; and ell grading disturbance are located ad}ecent to these <br />evaluations during the last two years~af the liability period <br /> <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 Erom the nearby <br />.. _____ „ ...__ r~_ __~-, _..__..., .,.._.,_.-. .. ...,_,.:.r~ .e.f.~ti.. ...d ~ntiinvahl> ee>ntl>rda that <br />