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C2009-087 3 8/28/2009 <br />However, in PAP Section 2.05.4(2)(d) (p.2.05-39), SCCC discusses replacing 130,000 cubic yards of <br />topsoil. This topsoil volume appears to be out of agreement. SCCC needs to explain why there is <br />an apparent 35,000 cubic yard discrepancy regarding topsoil stockpile SCM-001. <br />2.05.4(2)(c), (d), (e): The revegetation plan is found in PAP Section 2.05.4(2)(e). The proposed seedmix <br />contains a mix of grass, forbs and shrubs. There is no discussion regarding concentrated shrub planting, <br />strip seeding, fencing for shrub establishment, or other provisions to assist in shrub establishment. <br />There is a reference to implementing additional efforts if initial establishment looks poor for shrub (PAP <br />p. 2.05-41). <br />7) SCCC needs to define what level of establishment initiates additional measures. A statement that <br />establishment of a specified number, or frequency of shrub seedlings observed by a specified <br />year after seeding should clarify when additional shrub establishment efforts are warranted. <br />2.05.4(2)(e)(vi) Revegetation Success Standards: <br />8) On PAP page 2.05-51, SCCC proposes a shrub density standard of 200 stems per acre for the <br />Peabody Sage Creek Mine. SCCC needs to define if this proposed standard applies solely to the <br />areas expected to be re-disturbed by the Peabody Sage Creek operations, or to all of the <br />reclaimed areas included in the PSCM permit. The Seneca II permit currently has a 200 stems per <br />acre "background" standard on the reclaimed rangelands. However, the Seneca II shrub standard <br />also includes high density areas (concentrated shrub areas) with a woody stem density success <br />standard of 2000 stems per acre. <br />The reclaimed portions of the Seneca II Mine that are proposed to be transferred into the PSCM <br />needs to retain the woody stem density success requirement equivalent to that previously <br />approved for these reclaimed lands in the Seneca II Mine permit. That is, 200 stems per acre <br />"background" plus 2000 stems per acre in high density areas. Please assure that previously <br />approved reclamation success standards for the lands reclaimed under the Seneca II permit, and <br />transferred into the PSCM permit, retain the previously approved success standards. <br />Please provide additional explanation why a lower shrub density standard is being proposed for <br />those areas proposed to be disturbed under the PSCM permit, than what had been previously <br />approved under the Seneca II Mine permit (SCCC is proposing only the background shrub <br />density standard on the PSCM disturbance, yet the Seneca II disturbances had a background plus <br />a concentrated shrub density standard). <br />9) SCCC refers to Seneca II Mine's Bond Release Blocks (BRB) 1, 2, 3, 4, and 5 (PAP page 2.05-44). <br />However, the Division was unable to locate a map depicting the limits and location of the various <br />BRBs in the PSCM permit application package. If SCCC discusses defined land units in the PSCM <br />PAP, SCCC will also need to include a map or figure in the PSCM permit application that clearly <br />shows where the map units are located.