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C2009-087 2 8/28/2009 <br />2) Has SCCC conducted this additional sampling in early spring 2009? Please supply DRMS with <br />results of the 2009 sampling effort. <br />2.04.12: Prime Farmland Investigation. (page 2.04-150 )No croplands are within the proposed PSCM <br />disturbance area. Cropland does exist in the west portion of the permit area but not in areas proposed <br />for disturbance. NRCS has determined that no prime farmlands exist in Routt County due to cold <br />temperatures and short growing season. <br />Exhibit 2.09-E1 contains soils information, but no letter from NRCS documenting the "no prime <br />farmlands" determination. <br />3) Please incorporate documentation that NRCS has determined that there are no Prime farmlands <br />in the permit area. (SCCC needs to include letter from NRCS into the PSCM permit. It is not <br />adequate to reference this documentation in other permits.) <br />2.04.13: Annual Reclamation Report. <br />SCCC commits to submitting annual reclamation reports in accordance with Rule 2.04.13. <br />However, this commitment appears to begin once PSCM is permitted. SCCC is incorporating <br />previously reclaimed lands into the Peabody Sage Creek permit that have been reclaimed for <br />varying numbers of years, and have been approved for different phases of bond release. <br />Although the historical information regarding reclamation practices for these previously <br />reclaimed lands exists in the Seneca II permit, referencing this information is not acceptable for <br />the Peabody Sage Creek permit. <br />4) SCCC will need to incorporate the historic reclamation information pertaining to those lands <br />being included into the Peabody Sage Creek permit. The Division will also need one map showing <br />the year each of the reclaimed parcels were seeded and dates of any inter-seeding or re-seeding <br />occurred on any of the parcels. <br />5) SCCC will need to report reclamation information on the previously reclaimed lands incorporated <br />into the PSCM permit in future Annual Reclamation reports until those reclaimed lands have <br />received final bond release. <br />2.05.3(5) This section provides the proposed topsoil salvage and storage plan. In Section 2.05.3, SCCC <br />commits to using all stockpiled topsoil during reclamation of the disturbed areas. This implies that SCCC <br />will leave no topsoil piles at the end of reclamation. SCCC commits to replacement of 12 inches of <br />topsoil on proposed disturbed areas (PAP p. 2.05-39). <br />6) In Section 2.05.3 of the PAP (p. 2.05-28) SCCC states that there will be one topsoil stockpile, SCM- <br />001, located south of the proposed coal stockpile, consisting of 165,000 cubic yards of salvaged <br />topsoil.