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<br />im. ala <br />1?s Coal company <br />Seneca Coal Company <br />November 2, 2010 <br />Mr. Dan Mathews <br />Division of Reclamation, Mining and Safety <br />101 South 3`d, Suite 301 <br />Grand Junction, CO 81501 <br />(970) 243-1571 <br />REOFFIVED <br />NOV 0 <br />A# g and Sa *y <br />RE: Yoast Mine Permit No. C-94-082 <br />Permit Renewal (RN-03) - Revegetation Success Demonstration Clarifications <br />Mr. Mathews, <br />Seneca Coal Company (SCC) has reviewed your letter regarding RN-03 (dated October 6, 2010) and <br />has prepared the following responses. <br />1. On page 34 of'Tab 22, the 3rd paragraph states that the three dominant affected types in the permit <br />area are mountain brush, aspen woodland, and sagebrush, and that these three types would serve <br />as the basis for developing weighted averages for cover and production comparisons (for the <br />dominant reclaimed shrub grassland type). Narrative indicates that these three types occupied, <br />respectively, 48.9%, 24.4%, and 24.0% of the proposed disturbed area prior to mining. The steep <br />mountain brush type was noted as a minor community, occupying 2.7% of the disturbed area prior <br />to mining. <br />On page 35 and 36 of Tab 22, the detailed discussion and formula given for determination of the <br />cover standard for the reclaimed shrub grassland type in the reclaimed mine area differs from the <br />approach described on page 34, in that the minor steep mountain brush type is included in the <br />formulation of the weighted area cover standard. In contrast, the approach for herbaceous <br />production success demonstration for the shrub grassland type in the mine area (on page 38139) <br />uses only the three major types, which is in conformance with page 34 narrative. There would <br />seem to be no logical reason that the community used as the basis for the shrub grassland cover <br />standard should differ from the community types used as the basis for the shrub grassland <br />production standard. <br />Unless justification is provided for inclusion of the minor community (steep mountain brush) in <br />formulation oJ'the weighted average standard for cover, please revise the formula on page 35 to <br />eliminate the minor community component, for consistency with other portions of the section. <br />Also, please revise the formula to include the premine disturbed area acreage for each of the <br />three primary community types in the numerator, with the combined acreage for the three <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5217 a FAX (970) 276-5222