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REV96898
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REV96898
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Entry Properties
Last modified
8/25/2016 3:21:26 AM
Creation date
11/22/2007 12:04:29 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980005
IBM Index Class Name
Revision
Doc Date
1/10/2006
Doc Name
Adequacy Review
From
DMG
To
Seneca Coal Company
Type & Sequence
TR40
Media Type
D
Archive
No
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Mr. Roy A. Kazo <br />January 10, 2006 <br />Page 3 <br />initial bond release application is submitted, and that a plan for remedial <br />reclamation will be pursued. Please confirm that our understanding is <br />correct. <br />b) Numerous Tree Plot azeas aze delineated on the Exhibit. Our assumption <br />is that these areas are locations where planned shrub or tree planting was <br />conducted, and that these azeas do not necessazily correspond to the "shrub <br />concentration azeas" or synonymous "high density shrub patches", <br />referenced in subsequent sections of the appendix. Please confirm or <br />clarify as appropriate. <br />c) Directly south of Parcel 99-1f, in BRB-4, there is a reclaimed parcel that <br />includes a lazge Tree Plot area. The parcel does not appeaz to have a <br />date/number designation. Also, there is a parcel in BRB-4, at the extreme <br />southern end of the reclamation, that is designated 86-4e. If the pazcel <br />were reclaimed in 1986, it would logically be included in BRB-3. Please <br />address and correct these apparent discrepancies as appropriate. <br />4. The Logical Land Management Units (LLMU's) as described in the appendix and <br />delineated on Exhibit 13-13.2 comprise individually fenced pastures. These units <br />do not appear to correspond precisely with the Logical Land Management Units <br />terminology as described in the 1995 DMG Guidelines document. Under "Bond <br />Release Block Constraints", on page 14 of the Guidelines, a bond release block is <br />described as a grouping of reclamation pazcels that comprise or are contained <br />within a single logical land management unit. This does not appeaz to be the case <br />with respect to the BRB's and LLMU's as delineated on the map exhibits in the <br />appendix. For example, the BRB-3 bond release block appears to extend into 5 <br />separate LLMU's, as defined in the appendix (Cow Camp Pasture, Pecoco <br />Pasture, Wadge Pasture, Powder House Pasture, and Thompson 440 Pasture). <br />It may be the case that multiple pastures could be appropriately grouped into a <br />single LLMU, based on the factors described in Part 2 (pages 14 and 15) of the <br />Guidelines. If so, the necessary amendment may be limited to revision of the <br />narrative under "Logical Land Management Units", on page 2 of the appendix, to <br />describe and justify the inclusion of multiple designated pastures within a single <br />LLMU. If this is not the case, it may be necessary to further divide the proposed <br />bond release blocks, to create additional bond release blocks such that each BRB <br />is contained within a single LLMU. <br />Please review the referenced Guideline sections and amend the appendix as <br />necessary to demonstrate that the Bond Release Block/L,ogical Land <br />Management Unit framework of the appendix is in accordance with the <br />Guideline. <br />5. Under Sampling Design on page 2 of the appendix, it is stated that BRB-4 and 5 <br />blocks will be samples "similaz to BRB-3..." <br />
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