2010-01-22_REVISION - C1981008 (2)

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C-1981-008 PR-06 PAR 22-Jan-2010 Page 24 of 26 described in the P sentence of the previous paragraph in this item 19d. The remaining text and formulas in amended subsection 6.1.4 should be deleted. Please revise the subsection as requested, unless justification for an alternative approach can be provided. e) There are several erroneous components in the production success standard as summarized in the first paragraph of amended sub-section 6.1.5. First, there is reference to use of tons per acre for the success comparison. The level of precision is not specified, but production success is typically evaluated in pounds per acre. Second, the statement indicates that success would be demonstrated if reclaimed area production is equal to or greater than the standard in "at least 3 of 5 years". The basis for this is not clear, Rule 4.25.5(3)(c) states that success will be demonstrated "...when the adjusted 3 year average annual crop production is equivalent to, or higher than, the average yield of the reference crop established for the same period..." Thirdly, the narrative indicates that "reclaimed block production as measured by the total harvest method must equal or exceed 100% of the standard, with a 90% confidence interval". Because the demonstration is based on total harvest data rather than a sample of the bond release block production, reference to a specific confidence interval could create confusion. If success is demonstrated by direct comparison of total harvest data averages, the positive determination of revegetation success would by definition be made "with not less than 90% level of confidence", and as such would comply with Rule 4.25.5(3)(d). Unless justification can be provided for an alternative approach, please re-state the first paragraph of subsection 6.1.5 as follows: Revegetation will be deemed successful if the adjusted 3 year average annual I" cutting alfalfa hay crop production (expressed in pounds per acre) is equivalent to, or higher than, the 3 year minimum average annual 1" cutting production for the reference field, based on direct comparison of the reclaimed and reference site production averages. Rule 2.10 - Mans 62. The PR-06 application cover letter from Greg Lewicki & Associates says that many maps have been changed by the requested adjustment to the permit boundary, and are enclosed with the application. The application does not provide a specific list of those maps that are included for the sole purpose of updating the permit boundary. We have made the assumption that the following maps fall into this category: o Map 2.04.6-1 - Geologic Cross Section - Sample Locations o Map 2.04.6-7 - Coal Exploration Drill Holes o Map 2.04.9-2 - Topsoil Balance Map as of February 2008 o Map 2.04.11-1 - Wildlife %z Mile Vegetation Baseline o Map 2.05.3(3)-2 - Variance to Leave Turn Slot - Life of Operation