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Mr. Roy Karo <br />Seneca Coal Company <br />Page 2 <br />2004 Annual Reclamation Report <br />2. It appears from the information provided on pages 1 and 2 of the 2004 ARR, that the <br />specified average topsoil replacement thickness of LS feet for the mine area was not met <br />in 2004, and that stockpiled soil volume may be insufficient to meet the specified average <br />topsoil replacement thickness in the future. <br />Please address the reasons for the discrepancy with respect to average soil <br />replacement thickness in the 2004 reclamation area and for future reclamation <br />areas. Also, please provide a sketch or map of the 2004 reclamation parcel showing <br />soil depth sample locations and measured thickness for each location. <br />3. A copy of a seed tag, two certification letters from Granite Seed Company, and Table <br />04.2 were submitted, to document seed mix components used in the 2004 seeding. There <br />seem to be a number of contradictions and inconsistencies in the information submitted, <br />and between documentation submitted and the approved seedmix. <br />a) The approved mix specifies Secar bluebunch wheatgrass, whereas Table 04.2 specifies <br />beardless bluebunch (var. inerme). The seed tag and both certification letters specify <br />Secar bluebunch. Why does Table 04.2 differ from the other documents? <br />b) The approved mix specifies use of "Travois" alfalfa cultivaz. Seed tags and <br />certification letters indicate "Ranger" and "Ladak" alfalfa cultivars were seeded. The <br />renewal findings document indicates that "Travois" alfalfa was selected because of its <br />less aggressive tendencies, in compazison to other alfalfa varieties. Why were cultivars <br />other than the approved "Travois" seeded? <br />c) Seed tag and certification letters indicate that streambank wheatgrass was included in <br />the seed mix, but this species is not included in the approved seedmix, and is not listed in <br />Table 04.2 of the report. Please explain this discrepancy. <br />d) Rocky mountain penstemon is included in the approved seedmix, and is listed in Table <br />04.2 and the two certification letters. However, it is not listed on the seed tag provided. <br />Please explain this discrepancy. <br />e) Table 04.21ists a yarrow species (Achillea nigrescens), with which we aze unfamiliaz, <br />and which differs from the approved species, western yarrow (A. lanulosa). Certifccation <br />letters and the seed tag appear to indicate western yarrow (A. lanulosa) was seeded. <br />Pease explain this apparent discrepancy. <br />f) For a number of species (slender wheatgrass, orchardgrass, basin wildrye, Canada <br />bluegrass, Palmer penstemon, tailcup lupine) the cultivar (or species, in the case of <br />lupine) specified in the approved seed mix does not conespond to the cultivar indicated <br />on the seed tag. Please address the reason that the specified cultivars were not used. <br />