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Michael G. Altavilla Seneca Coal Company Page 3 November 24, 1998 9. The AVS lists the Lehman Merchant Bank, AVS entity ID no. 146466, as the owner of the P&L Coal Holdings Corporation. If this is true, in the list of officers and directors that had been submitted for the P&L Coal Holdings Corporation, please provide a revised submittal page that has the addition of Lehman Merchant Bank as the owner. 10. If Lehman Merchant Bank owns P&L Coal Holdings Corporation, please add Lehman Merchant Bank to the organizational chart that was provided in the submittal. 11. If Lehman Merchant Bank owns P&L Coal Holdings Corporation, please add Lehman Merchant Bank and its organizational information to Attachment 3-5 of the submittal. 12. As stated in your cover letter to this permit revision, additional adjudication information required for the II-W South area was not completed at the time of your application submittal. Please submit this information as soon as possible. The Division cannot approve this application package until all of the adjudication information has been received and reviewed for adequacy. 2.04.10 Vegetation Information 13. It is not cleaz from narrative in the Vegetation Information section or the Revegetation Plan, how the extended reference area comparisons will be affected by the South Expansion Area, and clarification is requested. In specific, it is not cleaz whether South Block reclaimed areas would be compared against acreage weighted extended reference azea data from the South Block mine area only, as depicted on Map 10-3, or whether the South Block extended reference areas would be "added on" to the currently approved permit area extended reference areas. On page 43, Section 10.2, under Background, it is stated that "all undisturbed native vegetation within the proposed Seneca II-W South Extension area will be used to develop a vegetation data set to be used for comparison to the reclaimed area vegetation data set." This would seem to imply that, for bond release comparisons, the South Extension area would be separately evaluated from other portions of the permit area, and that the two permit area blocks would be judged against two separate extended reference area data sets. However, narrative in Tab 22 seems to imply that undisturbed vegetation types in the current permit area and the South Extension would be combined into a single extended reference area. Further, on page 39 of Tab 22, there is an acreage breakdown of the '`four major vegetation types" to be used in the extended reference area comparison sampling.