REP48004

• Permit No: C1994082
• IBM Index Class Name: Report
• Doc Date: 9/8/2006
• Doc Name: 2005 ARR Review Letter
• From: DRMS
• To: Seneca Coal Company
• Permit Index Doc Type: Annual Reclamation Report
• Media Type: D
• Archive: No

Roy Karo
Seneca Coal Company
Page 2
c. The seeded acreage values reported are also inconsistent. The 2005 report
states that last year's cumulative total was 308.2 acres. The actual 2004
reported total was 296.2 which, when added to the 2005 acreage of 96.6
acres, should total 392.8. The 2005 report has a new cumulative total of
404.8 acres.
2. The text, on page 3, states that revegetated azeas were seeded with Seed Mix
#lA (Mesic Areas/Ephemeral Drainages), but the seed tags provided don't
fully support this statement. Seed tags provided document four mixes;
Concentrated Shrub Seeding Areas, Upland Sites Shrub Component,
Mesic/Riparian, and Upland/Bphemeral. The seed tag provided for the
Upland Sites/Bphemeral Drainages looks close to the approved Seed Mix
#lA, except that it does not include Blue Flax and Antelope Bitterbrush. A
seed tag was provided for Seed Mix #2, but the narrative of the report does not
mention whether this mix was used in any of the seeded areas. The seed tags
for concentrated shrub and upland shrub seeding do not match the approved
Seed Mix No. 5 for concentrated shrub areas, and they also include numerous
forb species. Were all of these mixes used? If so, in what combinations and
in which azeas?
3. Looking at the seed tags submitted it appeazs that SCC has included forbs in
the shrub concentration mix (as discussed with Dan Mathews of DBMS) but
SCC did not change the approved seed mix in the permit application package.
Please submit a minor revision to the pennit to update Seed Mix No. 5 to
include the forb species previously agreed upon with DRMS.
4. The seed tags are somewhat illegible, given the quality of the copy provided,
and there is also information missing on the bottom of the shrub seeding lists
(bulk lbs, PLS lbs) so we were not able to verify the correct seeding rates for
each species. In reviewing the Upland/Ephemeral tag (as noted above, it was
found to be similar to Seed Mix #lA), it seems that the ratio of species is not
consistent with the approved mix, although this maybe due to our inability to
clearly read the percentages of pure seed. Please review the seed tags and
provide documentation that the seed mixes used were consistent with the
approved mix, and provide details of the seeding rate and location(s) where
these mixes were used.
5. The text of the ARR, on page 3, notes that 18,200 seedlings were planted at
Yoast, the locations being shown on an attached map. The map notation
shows 20.5 acres of shrub plots. The average seedlings per acre, then, would
be 887.8. All of the approved planting lists (Table 22-8 of the approved
permit application package) call for a minimum of 4000 seedlings per acre.
Please explain why the seedlings were planted at less than the approved rate.
The species ratios planted are also inconsistent with the approved planting list;
this deviation should be explained as well.