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11. A separate cover standard is proposed for concentrated tree and shrub establishment sites. This would require statistically adequate cover sampling of these sites as a separate strata. Given the focus on establishment of woody plants in these areas and the fact that competitive herbaceous species are not seeded, we question whether this is warranted. Based on Table 22-10, the shrub establishment areas comprise less than 4% of the total reclamation acreage. We believe it might be more practical to include these small sites in the "sampling universe" for cover and production sampling associated with the larger reclaimed areas in which they are included, rather than requiring another separate layer of sampling requirements and standards. The influence of potentially low cover values within the shrub establishment areas would likely be minimal, (because the small areal extent would result in a relatively small number of sample points within the shrub establishment areas). Please give consideration to this approach, and provide a response and amended language, if you concur. 12. Please explainljustify the use of "first hit" herbaceous reference area cover for success determinations associated with mesic drainage, as opposed to "all hit" herbaceous reference area cover as described for the reclaimed uplands. 13. On page 43, there is reference to establishment of a production standard for haul road corridor permanent reclamation areas based on historical production records. Have statistically adequate samples been obtained from the various vegetation types over a period of several years, as required by Rule 4.15.71211d-Iv-? Please confirm and provide details if this is the case, or provide a specific plan for collecting the required data. Species Diversity 14. On page 44, there is discussion of the "competition-suppressed" forb and woody plant presence, to be considered in development is species diversity success testing approaches. Please give consideration to further modifications to the current reclamation plan that might be practicable to enhance diversity, while still providing acceptable erosion control. Such modifications might include seedmix amendments, modified seeding approaches, modified soil handling practices, modified grading approaches, modified management approaches, etc. 15. At the bottom of page 45, the example equation appears to be incomplete. The complete equation would appear to be [25.21-[(1.15)x5.3]=19.1. 16. We have two comments on the lifeform similarity index approach proposed as "Alternative Text B" on page 46. First, we believe the procedure would be clarified if "c" were defined as "the sum of the smaller of the paired species density values (for each life form) for reclaimed and reference areas". A second, and more significant concern, is that species density is proposed as the importance value to be tested, which is consistent with the proposal for Seneca II, but differs from the Seneca II-W proposal, in which cover was the selected importance value. Also, tour life forms were selected for the similarity testing in the Yoast and II-W proposals, but eight life forms were selected for Seneca II. Please consider these comments and amend the text as appropriate. Unless justification can be provided, we believe that the test components should be consistent among the three Seneca Coal Company permits.