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,, ice' T Michael G. Altavilla 1.~;~~~~~ Seneca Coal Company 13 Page Z April 23, 1999 the shrubs that are seeded. Tn Seed Mix IA chokecherry, serviceberry and snowberry (shrub species from the iVfixed Brush community) are used in place of the sagebrush and winter fat seeds used in lB. It is suggested that Seed Mix lA be the primary seed mix to reflect site conditions. Please revise Exhibit 22-1 and Table 22-10 to show a proportionately larger area of Seed Mix l A and a postmining vegetation type of predominately mixed brush. 2. No aspen reestablishment areas are proposed in the Sage Creek drainage area (Sections 19, 20, 29 or 30). The baseline Vegetation Map (Exhibit 10-1) and Revised Table 22-9 show aspen communities aze a dominant community to be disturbed in the Sage Creek drainage. DMG encourages SCC to evaluate where feasible locations may exist, especially along the disturbance boundary adjacent to existing aspen communities, and if feasible, include some aspen reestablishment areas in the Sage Creek drainage area. The number of estimated postmining acres for Mesic Drainage have been reduced. Revised Table 22-10 estimates 5.8 acres of postmining Mesic Drainage compared to 14.9 acres in the existing table. The number of acres proposed for Mesic Drainage Tree and shrub sites has also been reduced from 3.0 to 0.5 acres, although the total disturbed acreage has increased from 656 to 912 acres. Please discuss these changes and explain the reductions. 4. SCC states on page 22 (Tab 22) that the distribution of planting arrangements have been planned to keep wildlife travel distances between clumps or native vegetation to less than 1000 feet. The distances are larger than this in portions of the Sage Creek disturbed azea. Please revise Exhibit 22-1 to include more shrub areas. 2.05.6(3) Protection of Hvdroloeical Balance and 2.06.8 Surface Coal MInInE and Reclamation Oaerations on Areas, or Adjacent to Areas, Includine Alluvial Vallev Floors The following seven comments correspond to Questions 1 through 7 originally provided to SCC in our Division letter dated June 7, 1995. The following comments are in response to SCC's letter dated January 19, 1999 regarding these questions. 5. Response is accepted as stated in SCC's January 19, 1999 letter. 6. SCC asserts that the field in Section l8 upstream for the former Sage Creek Reservoir is not an alluvial valley Floor, based largely on the fact that irrigation observed at that site in 1995 was being done without proper water rights. Please note that, in order for the Division to find that this area is not an alluvial valley floor, we would need evidence that it meets none of the criteria found in Rule 2.06.8(3)(c)(I)(B). The Yoast permit currently indicates that the field is