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permanent mix in the fall, 1994 seeding, although the species had not been listed <br />as a cover crop species in the application. The species was subsequently added <br />to the cover crop species list, however observations made during the summer of <br />1995 by both Seneca and Division personnel indicated relatively poor initial <br />establishment of permanent species on the areas cover cropped with regreen. <br />Regreen was not used in the fall, 1995 planting season. These areas will be <br />monitored during the 1996 growing season and the future use of regreen as a <br />cover crop will be evaluated based on the 1996 field evaluations. <br />Revegetation success criteria, monitoring plans and methods of comparison for <br />testing revegetation success are addressed in Tab 22. Cover and production <br />success for the major mine area vegetation communities will be based on <br />weighted average reference area comparisons as described on pages 39-42 of Tab <br />22. The cover standard for mine area reclamation will be based on adjusted <br />weighted average reference area herbaceous cover. The reference area <br />herbaceous cover value will be doubled to set the success standard. For the <br />mine area vegetation this adjustment is deemed appropriate, because unadjusted <br />reference area herbaceous cover in the mine area vegetation types would be <br />insufficient to control erosion; whereas use of total cover would result in a <br />standard unlikely to be achieved for decades, given the dense canopy associated <br />with late successional shrub communities in the mine area. <br />Cover and production success for upland and lowland rangeland reclamation <br />areas in the tie-across haul road corridor will be based on direct comparison with <br />the low sagebrush and meadow reference azeas, respectively. Grain production <br />from reclaimed wheat cropland in the tie-across haul road corridor will be <br />compared to county average dryland wheat yield. <br />Species diversity standards for both mine area and tie-across haul road rangeland <br />reclamation are based on the life form comparison approach recommended in <br />the Division's land use and vegetation guidelines. The species diversity standard <br />for the mine area requires establishment of at least; three cool season grasses, <br />three forbs, four shrubs and one tree. Minimum and maximum cover is <br />described in further detail in Tab 22. Species diversity in the reclaimed areas <br />along the haul road is concentrated on the herbaceous component. <br />In response to a Permit Renewal 02 adequacy concern, the operator provided <br />additional detail regarding statistical tests of revegetation success. Revised page <br />39, Tab 22, clarifies that hypothesis tests and sample adequacy formulas <br />employed in success demonstrations "will be consistent with the Division's April <br />1995 Guideline Regarding Selected Coal Mine Bond Release Issues or the <br />current guideline in effect at the time of a bond release application." <br />As a part of PR #1, Seneca proposed a reduction in the mine area woody plant <br />density standard from the originally approved 1000 stems per acre to 450 stems <br />per acre. The proposed standard was not accepted by the Division, due to <br />concerns expressed by the Division of Wildlife (DOW) that wildlife habitat needs <br />36 <br />