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
2,,d Response to Adequacy Comments
Page 3
to boundary of the Seneca II permit area approved in PR-2. Appendix 13-13
revegetation success demonstration methods and success criteria which are
referenced in permit Volume 14 are applicable to the Seneca II permit area as
approved in PR-2. Revegetation success demonstration methods and success
criteria applicable to the adjacent Sage Creek permit area (portions of which
were within the original Seneca II permit area as it existed prior to PR-2) are
addressed in the applicable sections of Permit C-2009-087.
b. .83% and.17% in the second paragraph of the introductory section of
2.05.4(2)(e)(vi) should be changed to 83% and 17% respectively.
c. Add a new paragraph at the end of the 2.05.4(2)(e)(vi) introductory narrative
which states: all disturbed lands within the reduced permit area fall within Bond
Release Block 3 (BRB-3) or Bond Release Block 4 (BRB-4). A summary of
sampling designs and success demonstration approaches applicable to BRB-3,
BRB-4, and reference areas is presented under the "Sampling Design " Section of
Appendix 13-13. Note that BRB-3 and BRB-4 sample designs and criteria are
identical. Success criteria will be demonstrated for at least two of the last four
years of the liability period, in accordance with Rule 4.15.7(5).
d. Revise the "Cover Sampling" subsection as follows: Delete the entire narrative
and insert the following: Refer to the Cover Sampling section of Appendix 13-13.
Sampling will be conducted as describe therein. Cover sampling will be conducted
during July/August, and livestock grazing will be deferred until after sampling is
complete, in both reclaimed and reference areas.
e. Revise the "Production Sampling" subsection asfollows: Refer to the Production
Sampling section of Appendix 13-13. Sampling will be conducted as described
therein. Production sampling will be conducted during July/August, and livestock
grazing will be deferred until after sampling is complete, in both reclaimed and
reference areas.
f. Revise the "Reclamation Sample Adequacy assessment and Hypothesis Testing"
subsection as follows: Delete the entirety of the subsection narrative and insert:
sample adequacy and hypothesis testing approaches for first hit herbaceous cover
and herbaceous production will be conducted as described under the "Sample
adequacy Determination " and "Hypothesis Testing Approaches " subsections of
Appendix 13-13. An exception/clarification is that sample adequacy for cover will
be demonstrated based on first hit herbaceous cover.
g. Revise the "Species Diversity " subsection by deleting the entire narrative and
inserting: Please refer to the "Species Diversity " subsection of the "Assessment of
Reclamation adequacy " section of appendix 13-13, for a description of the species
diversity criteria. Diversity evaluation will be based on compliance with one
mandatory test and two of three optional tests, as described in Appendix 13-13.
Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639
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