2003-12-22_GENERAL DOCUMENTS - C1982057

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as coal haulage roads for the duration of operations. Full reclamation grading of the upper segment of Road A (the abandoned segment east of the Road H intersection) is to be completed by the end of 2005. Based on the Exhibit 19-I A reclamation schedule, full reclamation grading of Road [ is to be completed by the end of 2012; partial reclamation (width reduction grading) is to be completed by the end of 2005 for Road K, and by [he end of 2012 for Road H and Road J. It appears that the current schedule will need to be updated to accommodate continued coal haulage on lower Road A and the MEHR beyond 2005. Also, there would appear to be no reason for delaying reclamation of the abandoned upper segment of Road A, or partial reclamation of Road G beyond 2004. Please amend the backfilling and grading schedule of Exhibits 19-1 and 19-1A as appropriate, for the referenced road segments. Alsq please ensure that disturbance area boundaries are accurately delineated and properly labeled on the two exhibits. 35. The aspen study described beginning on page 23a of Tab 22, and Appendix 22-3, was not implemented in accordance with the approved schedule, and an enforcement action has been issued that requires submittal of an amended study plan and schedule by specified deadline. [n addition to the modified aspen transplanting study, [he Division has discussed with the operator certain alternative approaches to aspen establishment [o be considered for inclusion in the revegetation plan, that could be implemented independent of the formal transplanting study of Appendix 22-3. One approach discussed includes the "mother plant approach" for aspen planting as summarized on pages 23 and 23a of the approved permit. Although the permit narrative describes the "mother plant" approach for both tall shmb species and aspeq a commitment [o apply the approach operationally was not included for aspen. Another approach discussed for aspen planting would entail cutting of aspen within designated stands several years in advance of planned topsoil stripping, to create canopy openings and stimulate suckering to provide a site native source of aspen saplings. Please amend appropriate sections of Tab 22 narrative and tables to address aspen reestablishment approaches to be employed beginning in the 2004 field season, including the approaches described above. 36. Please clarify in the narrative on page 23c and Table 22-7 that concentrated tree and shrub planting areas will be seeded with Seedmix 6, in addition to the specified seedling planting. 37. Cover and production standards for the Seneca II-W mine area are based on extended reference areas established to represent major vegetation types in the permit area, including aspen forest, mountain brush, steep mountain brnsh, sagebrush/snowberry, and western wheatgrass/alkali sagebrush. Comparisons based on aspen forest and mountain brush reference azeas have proven to be awkward in northwestern Colorado, due to the impracticality of restoring similar community shvctures on reclaimed lands within de£med time frames. The Division has proposed regulation changes within a program amendment currently under review by OSM that would allow for the establishment of reference areas that reflect planned reclamation community structure rather than pre-mining community structure. The Division recommends that SCC consider submitting a revision to the permit to replace the aspen and mountain brush reference areas with reference areas more representative of the planned postmining vegetation structure, upon final approval of the referenced rote change. 38. Due in large part to the problems inherent in comparing grass dominated reclaimed areas to tall shmb or tree dominated reference areas, described m the above item, the cover standard for Seneca II-W incorporates various adjustments. Page 43 of the Division's current Findings of Compliance document contains the following statement: 17