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Permit Revision No.2 <br />Response to Adequacy Comments <br />Page 5 <br />comprehensive fashion within Appendix 13-13 of the approved application package. <br />However, Subsection 2.05.4(2)(e)(vi) of the PR-2 volume, beginning with the second <br />paragraph of the subsection on page 2.05.4-2, describes certain approaches and <br />methods that differ substantively from those specified in Appendix 13-13, in at least <br />two instances. The PR-2 narrative includes a proposal to base success for cover and <br />production using only the "sagebrush grassland" reference area, rather than an <br />average weighted comparison to "Mountain Brush/Aspen (83%) and "Sagebrush <br />(17%). Note that the current Seneca II permit does not identify a "Sagebrush <br />Grassland" reference area; for consistency the PR-2 narrative should instead refer to <br />the "Sagebrush " reference area. In addition the PR-2 proposal specifies that "all hit" <br />herbaceous cover would be used for cover success comparison rather than the <br />currently approved 'first hit herbaceous cover x 2 " approach. There may be <br />additional differences between the approaches currently approved in Appendix 13-13, <br />and those proposed in PR-2. <br />Please include an introductory narrative within subsection 2.05.4(2)(e)(vi) of the PR- <br />2 application volume, which clearly identifies all proposed changes in sampling and <br />statistical methods that would be used for demonstrations of revegetation success, as <br />compared to the currently approved methods as set for the in Appendix 13-13. <br />Provide the technical rationale and regulatory basis to support the proposed <br />changes Include a statement at the beginning of the subsection, indicating that <br />"With the exception of the following specific changes, the plan presented in <br />Appendix 13-13 Vegetation Evaluation Procedures for Testing Reclamation <br />Adequacy for Phase III Bond Release, remains in effect. <br />Response: The narrative has been revised as requested to be consistent with Appendix 13- <br />13. <br />15. Please revise the "testable hypothesis statement" at the end of the Shrub Evaluation <br />subsection to be consistent with the language of Appendix.13-3, as follows: <br />The density of full shrubs and trees will equal or exceed 90 percent of a <br />standard of 200 stems per acre in background areas and 90% of 2000 stems <br />per acre in concentration areas. <br />Also, for clarity, please add the following sentence following the hypothesis statement: <br />Shrub concentration areas are depicted on Exhibit 13-13.3 in Appendix 13-3. <br />There is a single shrub concentration area of approximately 6 acres within the <br />southwestern corner of the PR-2 reduced permit boundary. <br />Response: The narrative has been revised as requested. <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5217 • FAX (970) 276-5222