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Mr. Vern Pfannenstiel <br />August 28, 2009 <br />Page 5 <br />(p.2.05-39), however, discusses replacing 130,000 cubic yards of topsoil; this <br />topsoil volume appears to be out of agreement with the 165,000 figure. Please <br />explain the reason for this apparent 35,000-cubic yard discrepancy. <br />Section 2.05.4(2)(c), (d), (e) <br />23. The revegetation plan in Section 2.05.4(2)(e) proposes a seed mix of grass, forbs <br />and shrubs. There is no discussion regarding concentrated shrub planting, strip <br />seeding, fencing for shrub establishment, or other provisions to assist in shrub <br />establishment. There is a reference to implementing additional efforts if initial <br />shrub establishment looks poor (page 2.05-41). Please add text that defines what <br />level of establishment initiates additional measures. A statement that <br />establishment of a specified number, or frequency of shrub seedlings observed <br />by a specified year after seeding should clarify when additional shrub <br />establishment efforts are warranted. <br />Section 2.05.4(2)(e)(vi) <br />24. Page 2.05-51 proposes a shrub density standard of 200 stems per acre. Please <br />define whether this proposed standard applies solely to the areas expected to be <br />re-disturbed by PSCM operations, or to all of the reclaimed areas included in the <br />PSCM permit. Although the Seneca II permit currently has a 200-stems per acre <br />"background" standard on the reclaimed rangelands, it also includes high density <br />areas (concentrated shrub areas) having a 2,000-stems per acre standard for <br />woody stems. <br />The reclaimed portions of the Seneca II Mine that are proposed for transfer to <br />PSCM need to retain the woody stem density success requirement equivalent to <br />that previously approved for these reclaimed lands in the Seneca II Mine permit; <br />that is, 200 stems per acre "background" plus 2000 stems per acre in high density <br />areas. Please ensure that previously approved reclamation success standards for <br />the lands reclaimed under the Seneca II permit that will be transferred into the <br />PSCM permit, retain the previously approved success standards. <br />Please provide additional explanation as to why a lower shrub density standard is <br />being proposed for those areas proposed to be disturbed under the PSCM permit, <br />than what had been previously approved under the Seneca II Mine permit (SCCC <br />is proposing only the background shrub density standard on the PSCM <br />disturbance, yet the Seneca II disturbances had a background plus a concentrated <br />shrub density standard). <br />25. Page 2.05-44 refers to Seneca II Mine's Bond Release Blocks (BRB) 1, 2, 3, 4, <br />and 5. Please direct us to, or provide, a map depicting the limits and location of <br />the various BRBs. If the permit application discusses defined land units, then a <br />map or figure is needed in the application that clearly shows where the map units <br />are located.