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Mr. Mike Boulay <br />Department ofMinemlr and Geology <br />Page 3 <br />Response: The hisrorical (and future) fences that delineate the pastures within the Seneca II Mine azea were <br />established as logical land management units (for grazing purposes) prior to consideration for bond release. <br />SCC's review and interpretation of the Guidelines Regarding Selected Coal Mine Bond Release Issues, Part 2 <br />Bond Release Area belineation indicates that there is some contradiction within the criteria/definition for the <br />Logical Land Management Unit (iS.Mi~: <br />- Terminology <br />Logical Land Management Unit - `An area which may include one or mare bond release blocky, characterized by <br />uu form land use... ". SCC's delineation meets this criterion. <br />Bond Release Block Constraints - "...if the block cansuts of more than one parcel, the varzous pareelr mart together <br />comprire or be contained within a tingle logical land management unit': SCC's delineation does not conform to this <br />criterion. <br />- Logical Land Management Units - `The definition of logical land management unit will vary depending on the land <br />use and regionally accepted management pmctices.....For rangeland orpasturelanr~ a management unit would generally <br />cnrairt of a ringk `pasture"ora rmall numberafpastures utilized within a defznedgrazing rystem, de&mited by natural or <br />art~iial bamerr to livestock movement....': SCC's delineation meets this criterion. <br />SCC's delineation meets two of the three criteria. Based on the location of reclamation parcels, the logical <br />location of the pasture fences, location of property lines, and livestock water sources it is not possible to meet <br />the Bond Release Block criteria exactly. Review of the configuration and locations bond release blocks <br />(shown on Exhibit 13-13.1) indicates the complexity of assigning individual I.I.M[l's to each contiguous <br />group of redamadon parcels. Each of the current LLMU's consist of portions of two or more BRB's. SCC <br />will continue to use the LLMU's shown on Exhibit 13-13? with the understanding that assessment of each <br />BRB will consist of sampling within the boundazies of that particulaz block regardless of fence boundaries. <br />S. Under Sampling Design an page 2 of tfie appendix, it is hated that BRB1! and 5 blackr will he samples `nmilar to <br />BRB-3... „ <br />Foy clarity, please amend the statement m indicate that BRB11 and 5 will be sampled `5n <br />acrnrdance with the procedures described for BRB 3... " <br />Response: The text revision has been made. <br />G. On page 5 of the appendix, the General introductory dircussion underASSESSMENT OFRECLAMATION <br />ADEQUACYdercribes the extent to which quantitative data and statirtica! testing will be employed for BAB-1, BRB-2, <br />and BRB-3. <br />For consistency and clarity, please insert addidonallanguage mdicatutg that' in future bond <br />release applications, BRB-4 and BRB-5 assessments wi// be m acrnrdance with the procedures <br />described forBRB-3. <br />Response: The text has been revised. <br />7. In the first italicized paragraph under Cover and Production. on page 6 of the appendix, the traditional null hypothetic for <br />covertuccett testing it dercribed The second sentence notes that `Yhe factor of 2x...u contained in the Seneca Ilpemrit <br />document. " <br />