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Rule 2.05.3 <br /> 9. Please make any necessary changes to Table 12-2 if annual coal production for Seneca II- <br /> W amounts have changed since the last permit renewal. Also, please update the <br /> Operations Plan (Exhibit 12-2), if deemed appropriate. <br /> Rule 2.05.4(2)(d) <br /> 10. Soil replacement thickness data has been reported in each of the annual reports, as <br /> required. 1995 and 1996 reports indicated average replacement thickness of 16", which is <br /> the required topsoil replacement thickness. The 1997 average replacement thickness was <br /> 12.4", based on DMG sampling (refer to 1997 ARR). Please provide an explanation <br /> regarding the apparent lower replacement thickness for the 1997 topsoiled area. No <br /> acknowledgment or explanation for the lower replacement thickness was provided in the <br /> 1997 ARR. <br /> Rule 2.05.4(2)(e) <br /> 11. There appears to be a discrepancy between"Seedmix 1", in the permit (revised 5/95), and <br /> the seedmix listed in the annual reclamation reports. No explanation is provided in the <br /> reports for why the approved mix was altered. In the permit application, Mix 1 contains <br /> 11 grasses, 8 forbs, and 4 shrubs, and permit narrative states that any substitutions will be <br /> chosen from "adapted and desirable native species" listed in the baseline data species list. <br /> Permit narrative further states that such changes would be noted in the ARR, and <br /> indicates that "substitutions will only occur when availability of any of the listed species <br /> is a problem." <br /> The seedmix listed in the ARR's contains 12 grasses and 4 forbs, plus "supplemental" <br /> species including 5 forbs and 6 shrubs. Species included in the ARR list which are not in <br /> the approved permit seedmix include the introduced grass, Russian wildrye, and the <br /> introduced leguminous forb, cicer milkvetch. Two native grasses, slender wheatgrass and <br /> basin wildrye, are seeded at lower rates than specified in the approved mix. One native <br /> forb included in the approved seedmix (arrow leaf balsamroot) is not listed in the ARR <br /> specified mixes. <br /> Seedmix changes are not addressed or explained in the annual reports. Please provide an <br /> explanation for these discrepancies. Please ensure that the approved seedmix is used in <br /> 1998 and future seeding, unless the seedmix is amended through appropriate revision to <br /> the permit. <br /> 6 <br />