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SE? Seneca Coal Company <br />June 15, 2010 <br />Mr. Dan Mathews <br />Division of Reclamation, Mining and Safety ?p <br />101 South 3`d, Suite 301 <br />Grand Junction, CO 81501 <br />(970) 242-5025 <br />RE: Yoast Mine Permit No. C-94-082 <br />Technical Revision (TR48) - Aspen/Woody Plant Density Standard <br />Re-submittal and Response to Comments <br />Mr. Mathews, <br />Seneca Coal Company (SCC) has reviewed your Determination of Incompleteness letter of April 15, 2010 <br />and is submitting this package to address your concerns about aspen/woody plant density standards. <br />Responses to your items of concern are presented below. <br />1. The woody plant density standard proposed would retain an "overall " standard of 200 woody <br />plant stems per acre, but would limit the requirement for a "concentrated aspen/woody plant <br />planting area" standard to six fenced shrub plots (concentrated aspen/woody plant sites) shown <br />on Exhibit 20-2, postmining Topography Map. It is not clear why the revision references the <br />Postmining Topography Map, rather than Exhibit 22-1, Postmining Vegetation Map. Exhibit 22-1 <br />depicts three aspen establishment sites designated "to be fenced ", plus three upland shrub <br />planting areas designated "to be fenced ", and one Mesic drainage tree and shrub site "to be <br />fenced " (a total of seven, rather than six fenced planting sites). At least one of the aspen sites <br />depicted on Exhibit 22-1 has not yet been established (due to remaining reclamation grading to be <br />completed in the lower Pond 012 drainage). <br />Specific locations to which the proposed "concentrated aspen/woody plant site" standard would <br />apply should be defined by reference to Map Exhibit 22-1, which includes proposed, as well as <br />existing woody plant establishment sites Revision of narrative and Exhibit 22-1 is warranted to <br />provide for the necessary clarification. The revised map should depict the current <br />configuration of existing planting sites, should list date of planting for the various shrub and <br />tree planting sites that have been established, and planned year of planting for those sites that <br />have not yet been established Explanation should be provided regarding changes with respect <br />to number, type, and extent of woody plant establishment sites as compared to the currently <br />approved version of Exhibit 22-1. <br />Response: The narrative and Exhibit 22-1 have been revised. <br /> <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222