2010-11-30_REVISION - C1980005

• Permit No: C1980005
• IBM Index Class Name: REVISION
• Doc Date: 11/30/2010
• Doc Name: 2nd Response to Adequacy Comments
• From: Seneca Coal Company
• To: DRMS
• Type & Sequence: PR2
• Email Name: SLB
• Email Name: SB1
• Email Name: DTM
• Media Type: D
• Archive: No

Permit Revision No.2
2114 Re ponce to Adequacy Comments
Page 2
12. Resolved
13. Resolved
14. In this item, the Division had noted a number of inconsistencies between the
revegetation success demonstration methods and criteria described in Appendix 13-13
of the approved PAP and the success demonstration methods and criteria as described
in Section 2.05.4(2)(e)(vi) of the PR-2 narrative, and clarifications were requested.
The revised text is still quite confusing, and contains internal inconsistencies as well as
inconsistencies with Appendix 13-13. For example, the cover standard as presented in
Appendix 13-13 is -90% of TWICE the weighted reference area first hit herbaceous
vegetation cover ". Certain sections of the relevant narrative in the amended text are
consistent with this criterion, but subsequent sections make reference to "all hit"
herbaceous cover. Statistical formulas are largely consistent with corresponding
formulas presented in Appendix 13-13, but there are certain discrepancies which result
in a lack of clarity.
If the intent is that the revegetation success criteria and sampling/statistical methods
for demonstration of success are to remain largely consistent with those set forth in
Appendix 13-13 (which appears to be the case), then we have the following
recommendations.
a. Delete the extraneous section heading "Revegetation Success Sampling and
Evaluation ", and underline " 2.05.4(2)(e)(vi) Determining Revegetation Success "
to denote that it is a major section heading. The reference to Appendix 13-13
should be moved to become the second sentence of the third paragraph in the
introductory text under the 2.05.4(2)(e)(vi) section heading, but should be as
follows:
The plan presented in Appendix 13-13 Vegetation Evaluation Procedures for
Testing Reclamation Adequacy for Phase III Bond Release, remains in effect,
with the exception certain clarifications presented in this Section 2.05.4(2)(e)(vi)
of Volume 14. Sampling and statistical methods and success criteria for
vegetation cover for Phase II bond release are consistent with the methods and
criteria described for Phase III bond release, with the exception that vegetation
cover success for Phase II release requires data for only a single year.
It is important to note that vegetation sampling for bond release success .
demonstration for the Seneca 11 permit area will be conducted completely
independent of vegetation samplingfor bond release success demonstration in
the adjacent Sage Creek permit area (which was originally apart of the Seneca
II permit area). This means that any Phase II or Phase III bond release
applications for the Seneca II permit area will be supported by statistically valid
vegetation data collected from reclaimed lands contained entirely within the
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