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Seneca Coal Company <br />Phase II Bond Release Request <br />May2008 <br />species composition. The proposed release areas and evaluations are consistent with the <br />requirements of Rule 3.03.1(2)(b) and rule 4.15.8. <br />The total allowable herbaceous cover for the reclaimed and reference areas, as described in the <br />approved Seneca II permit, is derived from the total vegetation cover adjusted by subtracting <br />noxious weeds, if any, and annual plant cover in excess of 10 percent relative cover. Any shrub <br />cover is then subtracted to arrive at the herbaceous cover used for evaluation of success. For <br />BRB-2, the 46.1 percent allowable cover value equates to total vegetation cover of 49.7 percent <br />minus 0.1 percent noxious weed cover and 3.5 percent shrub cover. In BRB-3, 44.9 percent <br />allowable cover resulted from subtracting 0.2 percent noxious weed cover and 1.9 percent shrub <br />cover from 47.0 percent total vegetation cover. In the BRB-4 sampling area, total allowable <br />cover of 28.8 percent was derived by subtracting 0.7 percent noxious weed cover, 0.8 percent <br />shrub cover and 3.6 percent excess annual/biennial cover from the 33.9 percent total cover. <br />The approved cover success standard for the Seneca II mine is two times the allowable <br />herbaceous cover of the mountain brush and sagebrush reference areas and then weight averaged <br />(based on relative community composition) to determine the success standard. Mountain brush <br />adjusted herbaceous cover equals 79.1 percent total vegetation cover minus 64.2 percent shrub <br />cover minus 0.7 percent noxious weed cover times two, or 28.4 percent. Sagebrush adjusted <br />herbaceous cover equals 64.7 percent total vegetation cover minus 30.0 percent shrub cover <br />times two, or 69.4 percent. There were no noxious weeds. <br />The reference area derived cover success standard is: 0.90 (28.4 (0.83) + 69.4 (0.17)) = 31.9 <br />percent. Note: Mountain brush occupied 83 percent of the disturbed area pre-mine and <br />sagebrush occupied 17 percent of the area. <br />Sample adequacy was met for the reclaimed area parcels and reference area sampling. The results <br />are summarized in the following table. <br />7 <br />