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/'•- i +~ Seneca Coals Ltd. has provided a copy of the Emission Permit from the Colorado Department of Realth, found in Volume VII, Tab 14, p. 19-3. The application is in compliance with Rules 2.04.8, 2.05.9(2)(h), 2.05.6(1) and 9.17. X. TOPSOIL The permit area is occupied by three soil orders; MollisoZs, En tisols, and Aridisols. The presence of these three orders is characteristic of the soils found in steep, semi-arid regions of Northwestern Colorado. These orders represent soils that grade from recently developed soils with minimum horizon development to more developed soils with well-developed diagnostic horizons. Soils in the Aridisol order contain heavy concentrations of 2:1 layer clays of the smectite group. Heavy clay concen- trations of this type present certain management problems and reduce their suit- ability as topsoil material due to the shrink-swell potential exhibited by these clays. Also, slope steepness and the presence of coarse fragments are limiting factors in topsoil salvage operations within the permit area. Seneca II proposes stripping topsoil in single lifts prior to any disturbance. Topsoil will either be re-distributed immediately or stockpiled depending on pit advance and reclamation activities at the time of salvage operations. Stockpiled topsoil wi21 be protected from wind and water erosion by a quick growing vegetative cover. Single 1ift~stripping will mix different soil orders and serve to dilute heavy clay concentrations. With this in mind, slope steepness becomes the most important limiting factor in the salvage operation. The topography found within the permit area is such that steep slopes (40-60q) are frequently encountered. Slopes of this nature prohibit the use of heavy equipment needed for topsoil salvaging operations. The operator is able to salvage topsoil in some of these areas using a dozer, but in some cases, this method may not be possible. Therefore, the following stipulation is necessary: SENECA COALS LTD. MUST CONTACT THE DIVISION TO OBTAIN A VARIANCE FROM TOPSOIL SALVAGE IN AREAS WRERE SLOPE STEEPNESS PROHIBITS THE USE OF HEAVY EQUIPMENT NEEDED TO SALVAGE TOPSOIL. With the acceptance of the stipulation, Seneca II is in compliance with Rules 2.09.9, 2.05.3(5), 2.05.4(2)(d) and 4.06. Information demonstrating compliance can be found in Volume IV, Tab 9, Volume VI, Tab 12, p. 12-28, Volume VII, Tab 13, p. 13-6. XI VEGETATION The vegetation on the Seneca II permit area is characterized by mixed mountain shrub- Zand, upland sagebrush shrublands and aspen stands. The mixed mountain shrub type, located throughout the entire area, is dominant, covering 61e of the permit area. The upland sagebrush type covers approximately 13% of the permit area on welt-drained soils in the southwestern section of the permit area. Aspen stands, covering 4~ of the permit area, are located in South and East facing draws at higher elevations. The composition of the understory is similar to that of the mixed shrub type; there- fore, the aspen stands are classified as a subtype of the mixed shrub type. 220 of the permit area is classified as disturbed land. The vegetation baseline data is found in Volume V., Tab 10.