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C2009-087 <br />2/2/2010 <br />d) A map showing the year each of the reclaimed parcels was seeded and the dates of any inter- <br />seeding or re-seeding that occurred on the parcels. <br />SCCC provided this information of Map 2.04-13-M1. SCCC's response to 16 d) is adequate. <br />22) Section 2.05.3 of the PAP (p. 2.05-28) explains there will be one topsoil stockpile, SCM-001, located <br />south of the proposed coal stockpile, consisting of 165,000 cubic yards of salvaged topsoil. Section <br />2.05.4(2)(d) (p.2.05-39), however, discusses replacing 130,000 cubic yards of topsoil: this topsoil <br />volume appears to be out of agreement with the 165,000 figure. Please explain why there is an <br />apparent 35,000 cubic yard discrepancy . <br />SCCC has provided corrected topsoil salvage and replacement volumes on PAP pages 2.05-28 <br />(12/17/2009) and 2.05-39 (12/17/2009). This response is acceptable. <br />23) The revegetation plan in PAP Section 2.05.4(2)(e). The proposed seedmix contains a mix of grass, <br />forbs and shrubs. There is no discussion regarding concentrated shrub planting, strip seeding, fencing <br />for shrub establishment, or other provisions to assist in shrub establishment. There is a reference to <br />implementing additional efforts if initial establishment looks poor for shrub (PAP p. 2.05-41). <br />Please add text that defines what level of establishment initiates additional measures. A statement <br />that 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 />SCCC has provided appropriate responses to this concern. SCCC's response is acceptable. <br />24) Page 2.05-51 proposes a shrub density standard of 200 stems per acre for the Peabody Sage Creek <br />Mine. Please define if this proposed standard applies solely to the areas expected to be re-disturbed <br />by the Peabody Sage Creek operations, or to all of the reclaimed areas included in the PSCM permit. <br />The Seneca II permit currently has a 200 stems per acre "background" standard on the reclaimed <br />rangelands. However, the Seneca II shrub standard also includes high density areas (concentrated <br />shrub areas) with a woody stem density success 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 approved <br />for these reclaimed lands in the Seneca II Mine permit. That is, 200 stems per acre "background" <br />plus 2000 stems per acre in high density areas. Please assure that previously approved reclamation <br />success standards for the lands reclaimed under the Seneca II permit, and transferred into the PSCM <br />permit, retain the previously approved success standards. <br />SCCC references the Seneca II success standards and incorporate in Exhibit 2.05.4-E1 for lands <br />disturbed and reclaimed under the Seneca II permit. This is acceptable. <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 density <br />standard on the PSCM disturbance, yet the Seneca II disturbances had a background plus a <br />concentrated shrub density standard).