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Review Comments on the Seneca II Bond Release Sampling and Evaluation Proposal [Vegetation Evaluation Procedures to be used in Testing Reclamation Adequacy for Phase Ill Bond Release at Seneca 11 Mine - 2005 (/2006)] 1. We have some concern with the fact that SCC's plans involve collecting data this year to define the new success targets for woody plant density and species diversity, at the same time that data is being collected to demonstrate success. As you know, there is no guarantee that the proposed standards will be approved. The Division of Wildlife will be involved in the review and approval of the revised shrub density standard. It is possible that there will be concerns with the distribution or extent of high density patches, the proposed "high density patch" standard, or the proposed over-all density standard, with respect to wildlife habitat benefits. If this is the case, SCC might ultimately be required to undertake remedial efforts, such as interseeding or establishment of shrub patches in additional locations. As such, the woody plant density data collected in 2005 may not be accepted as a demonstration of woody plant success, and Phase III bond release in 2006 would be precluded. If SCC does pursue bond release sampling in 2005, the technical revision application defining and justifying the proposed amended success standards, sampling plan, and testing approaches, will need to be submitted and the Division's decision will need to be issued prior to submittal of the bond release application. Further, our recommendation is that vegetation sampling for bond release success demonstration be deferred until after the decision has been issued, to minimize the potential for unnecessary data collection. 2. In the Introduction and the section that follows, the document presents the case for breaking the reclamation into three bond release blacks for the bond release application under consideration. In general, the plan to define the blocks based on defined timeframes relative to regulatory programs in effect at the time of reclamation makes sense, and appears to be in accordance with DMG written guidance documents. Quantitative data collection requirements and required sample size, and success demonstration standards and approaches would differ for each bond release block. Our understanding of the general proposal is outlined in the table on the following page. Please review the table and confirm/clarify as appropriate. BRB-1 BRB-2 BRB-3 Quantitative Cover Sampling X (Max 20) X (Sample Adq.) X (Sample Adq.) (or Min. 30 for (or Min. 30 for reverse Null?) reverse Null) Quantitative Prod. Sampling X (Max 20) X (Sample Adq. X (Sample Adq. Or Min. 30 for Or Min. 30 for Reverse Null?) Reverse Null) Species Density Sampling X (Max 20) X (Sample Adq.) X (Sample Adq.)