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Mr. Dan Manhewr <br />Divirian afMinmak and Geology <br />Febroary 24, 2002 <br />Page 3 <br />The Division should note that the conditions and characteristics of the II-W mining azea aze not <br />"typical" of most coal mines. Due to the long narrow mining areas, SCC does not always have the <br />opportunity or the economics for conducting direct haul topsoiling or the live clump replacement <br />of trees and shrubs. <br />Comment 9 -Amore detailed plan is requested to manage and mordtor for weeds <br />currendypresentond to detect and control invasion ofanynew noxious species. <br />There is no reference to watching for and grubbing out any new noxious species on <br />the property. Henbane and other biennials reproduce by seed and should be <br />controlled bygrubbing prior to seed fomtation when they occur as individuals or small <br />patches. <br />Response: Details of the weed control plan have been included in Tab Z2, in the Weed and Pest <br />Control section. <br />Comment 10 -Update drawing 21-1 to show PR-3 replacement areas. Note one location <br />marked 1.0 feet should possibly be Z7 feet. <br />Response: Exhibit 21-1, Topsoil Replacement, has been revised to correctly indicate [opsoil <br />replacement depths. <br />Comment 11-Update to Table 21-1 seems to be missing information. Tab/e messed up. <br />Response: Table 21-1 has been edited and is included in this package. <br />Comment 12 - Direcr haul topsoiling for south mine area....text says logistics will <br />probablypresent opportunityforlive handling (direct haul). <br />Response: Please refer to Tab 22, page 28 and response to Comment 8 for a discussion of the <br />logistics and applicability of live handling topsoil. <br />Comment 13 -Modify seedbed preparation on long steep slopes (4:1 or greater) to <br />minimize erosion i.e., extensive roughening and broadcast seeding, short length <br />contour furrows, etc. Letter commits to gouging/pockingi but seedbed area section of <br />application not provided. Needs to be pretty detailed. <br />Original Comment _- Arear of relatively extenrive till erorion have been abretved an intently toproiled, <br />long, rteep rlaper at Seneca ll mine, and rimilar dope conditionr will be encountered within the ll-W South, <br />PR-3 area Pleare amend the Seedbed Preparation rection of the application to addrerr mearurer that will be <br />cmplayed to minimize erorion on rteep inclamation doper (eg. 4:1 or rteeper) during the initial years of <br />reve8etation ertablirhment. Poxible approaches which have proven raccerrful in rimilar rituationr at other <br />Cohrado mineriter, include extenrive rurfate roughening by track-hoe or doZergauging or rontour doer ripping, <br />or a combination of there techniguey followed by hydroreeding or bmadtart reeding,• or, for ure with drill reeding, <br />a combination of diverrion ditcher at intemak along the dope along with rontour chireling and/or t/ore/y rpaced, <br />rbort length (eg. 10), off-ret rontourfurrow.r. <br />Response: The text in Tab 22, Seedbed Prepazation, has been revised. However, it is very <br />difficult to be detailed when talking about dozer dips and track hoe humps. With reference to <br />erosion, Tab 22 also discusses maintenance of rills and gullies. <br />w.mru®~.rmuwrr.~rw,~rem, v..,r ,wp.,, <br />~,i,.i~ <br />