2010-01-25_APPLICATION CORRESPONDENCE - C2009087

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All revised or new materials to support these changes or modifications are included in the revised PAP materials. Section 2.05.3(5) 22. Section 2.05.3 of the permit application (p. 2.05-28) explains there will be one topsoil stockpile, SCM-001, located south of the proposed coal stockpile, consisting of 165,000 cubic yards of salvaged topsoil. Section 2.05.4(2)(d) (p.2.05-39), however, discusses replacing 130,000 cubic yards of topsoil; this topsoil volume appears to be out of agreement with the 165,000 figure. Please explain the reason for this apparent 35,000- cubic yard discrepancy. SCCC Response: The discrepancy has been addressed as a result of the changes to the operating plan and facilities redesign as noted in response to comment 21. The volume now is 140,000 cubic yards. Text pages 2.05-28 and 2.05-39 have been revised and are in agreement and are included in the revised PAP materials. Section 2.05.4(2)(c), (d), (e) 23.The revegetation plan in Section 2.05.4(2)(e) proposes a seed mix of grass, forbs and shrubs. There is no discussion regarding concentrated shrub planting, strip seeding, fencing for shrub establishment, or other provisions to assist in shrub establishment. There is a reference to implementing additional efforts if initial shrub establishment looks poor (page 2.05-41). Please add text that defines what level of establishment initiates additional measures. A statement that establishment of a specified number, or frequency of shrub seedlings observed by a specified year after seeding should clarify when additional shrub establishment efforts are warranted. SCCC Response: The PSCM revegetation plan (Section 2.05.4(2)(e)) has been modified to provide more detail for a shrub establishment plan including practices to assist in or enhance shrub establishment and a plan for monitoring and augmenting the shrub establishment effort as necessary. Additionally, two new tables have been added that list species to be seeded and planted in the shrub concentration areas. These new tables are 2.05.4-T4 "PSCM Concentrated Shrub Area Seed Mix' and 2.05.4-T5 "PSCM Concentrated Shrub Area Planting List". These replace the previous T4 and T5 tables in order to keep the shrub seeding and planting tables associated with the shrub establishment plan of the revegetation plan text. A completely revised revegetation plan section (2.05.4(2)(e)(i-v) is included in the revised PAP materials. Please note that the revised revegetation plan section and the drill site reclamation mix also addresses CDOW comments received by CDRMS in late 2009 and summarized by Janet Binns to Tom Kaldenbach on December 16, 2009. Section 2.05.4(2)(e)(vi) 24.Page 2.05-51 proposes a shrub density standard of 200 stems per acre. Please define whether this proposed standard applies solely to the areas expected to be re-disturbed by PSCM operations, or to all of the reclaimed areas included in the PSCM permit. Although the Seneca II permit currently has a 200-stems per acre "background" standard on the reclaimed rangelands, it also includes high density areas (concentrated shrub areas) having a 2,000-stems per acre standard for woody stems. 7