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E <br />Sco~comQ,trr Seneca Coal Company <br />December 27, 2006 <br />Mr. Mike Boulay <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Deriver, CO 80203-2273 <br />RE~~/V~~ <br />SEC 2~ <br />Division of p 2006 <br />Mining and Sa ety °n. <br />RE: Seneca II Mine Permit G80-005 <br />Technical Revision No. 40-Vegetation Evaluation Procedures for Phase III Bond Release <br />3b Response to Adequacy Comments <br />Dear Mr. Boulay, <br />Enclosed please find three (3) copies of revised and supplemental information for TR-40, corresponding to <br />the Division's adequacy review letter of December 5, 2006. The responses to the adequacy comments aze <br />provided below and are numbered accordingly. <br />DBMS advises that SCC not wait until final bond rekare application it imminent to map and rampk shrub croncentration <br />areas within Block 4. Mapping of the devekping rhrab areas rhould be fearibk byyear S (2008 for the mart rzcently reeled <br />areas). Delineation of the developing rhrub rtandr and interim shrub density rampling witha'n the block would allow for <br />assersmenJ of the apparent potential for compliance with the approved standard and ident~cation of the need for remedial <br />mearurer (:f anyJ within a reasonable time period lY/e would recommend that the interim monitoring plan be revised to <br />rubstitute shrub concentration aria mapping and shrrrb denrity sampling within Black 4, for the current parcel rpeciftc <br />monitoring, on a periodic bash beginning in 2008. Please revise the interim revegetation monitoring plan <br />to include periodic shrub concentration area mapping and shrub density sampling for Block 4, <br />beginning m Zr708. <br />Response: Shrub concentration mapping and delineation has been conducted over blocks 2 & 3. (See 2005 <br />annual revegetation monitoring report.) It is SCC's contention that Block 4 will be similaz. A concerted <br />effort to establish shrubs has been undertaken in Block 4. (See 2005 cluonological revegetation map for <br />location of shrub establishment azeas.) Please note the plethora of undisturbed islands throughout the mined <br />area, Exhibit 13-13.3. Note also, that Block 4 has edge contact with natural undisturbed mouatain shmb <br />community, for natural invasion oEwoody spedes. The trend noted by SCC over the past 20 years of <br />monitoring (see attached chart) shows that five years of growth may not be long enough to indicate the need <br />Eox remedial measures such inter-seeding or planting. Hence, SCC remains committed to years 2, 4 and 7 Eor <br />monitoring for remedial actions and yeaz 9 for final bond release monitoring. During the 2006 field season a <br />large portion of Block 4 was inter-seeded (Letter of July 18, 2006 seed mix) along the final Wolf Creek Pit. <br />The bulk of Block 4 was originally seeded in 1998 & 1999 so we aze approaching year 9 monitoring over the <br />next two years, anyway. <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (870) 276-3707 . FAX (870) 2763014 <br />