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C -1981 -008 - SL -12 <br />Preliminary Adequacy Review <br />26 May 2010 <br />Page 4 of 7 <br />The paragraph following the table must be amended to describe the statistical basis <br />for the conclusion that the cover criteria were achieved. In addition, the narrative <br />must include a statement confirming that the vegetation established on the reclaimed <br />area supports the approved land use. Species composition data from the BIO- Logic, <br />Inc. report, would be the primary basis for the statement affirming that the vegetation <br />supports the approved land use. <br />4. The cover table in the Appendix B, Phase II Vegetation Sampling report is a working <br />spreadsheet. It provides all of the necessary data to allow for statistical calculation and <br />technical evaluation; however a final summary table needs to be included in the report. <br />The summary table should be of the general form provided in Attachment 1 to this <br />memorandum. The purpose of the table is to provide a clear and accessible summary of <br />the cover and composition of the sampled parcel. The table should list each plant species <br />by common and scientific name, a column for relative vegetation cover by species, a <br />Total Vegetation Cover Column, and the "Total Desirable" Column. Please provide a <br />Summary Cover table, in the general form requested. <br />In accordance with the bond release guideline (p. 5), please provide a narrative summary <br />of the reclamation and management history of the parcels included in the Phase II release <br />request. <br />6. Please provide specific information regarding topsoil/subsoil replacement requirements <br />and thicknesses applicable to the Phase II release parcels, and provide narrative <br />explanation (based on sample data) to support the conclusion that the required <br />replacement thickness was achieved. List the soil thickness sample points on Map R -2 <br />that fall within the Phase II release areas, along with the thickness measured for each <br />point. All of the soil thickness sample points within the Phase II area must list a <br />measured soil thickness; please provide any missing data. <br />Phase III Band Release Request <br />WFC has requested Phase III release for 126.1 acres of irrigated pasture and 23.8 acres of <br />dryland pasture that were initially revegetated in 1998. The Division allows for Phase III bond <br />release upon successful completion of all reclamation plan requirements for the area in question, <br />including demonstration of conformance with all applicable revegetation success criteria. <br />Regulatory criteria are specified in Rules 3.03.1(2)(c) and 3.03.1(4). Achievement of <br />compliance with applicable revegetation success criteria must be demonstrated for at least 2 of <br />the last 4 years of the minimum 10 year liability period, with year 9 being the initial allowable <br />comparison year. Additional information to be provided in a Phase III bond release application <br />is addressed in the Division's Guideline Regarding Selected Coal Mine Bond Release Issues. <br />Success demonstration sampling for the Phase III request areas in SL -12 was conducted in 2007 <br />(Year 9) and 2008 (Year 10). <br />7. Pages 26 through 28 of the application were revised in a submittal dated 319110 to <br />incorporate discussion and a table ( "Soil Correction Table ") regarding a soil factor <br />adjustment procedure allowed under the approved permit [approved in TR -58], for <br />comparison of Irrigated Pasture (IP) reclaimed area production to reference area <br />production. The soil factor adjustments were not applied and were not necessary to <br />