2011-08-02_REVISION - C1982057

• Permit No: C1982057
• IBM Index Class Name: REVISION
• Doc Date: 8/2/2011
• Doc Name: Response to Re-submittal Comments
• From: Seneca Coal Company
• To: DRMS
• Type & Sequence: TR70
• Email Name: SLB
• Email Name: SB1
• Media Type: D
• Archive: No

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10 ENECA
Coal Company
August 30, 2011
Ms. Susan Burgmaier
Division of Reclamation, Mining and Safety
1313 Sherman Street, Room 215
Denver, CO 80203
RE: Seneca II -W Mine (Permit C- 1982 -057)
TR -70, Aspen/Woody Plant Density Standards
Response to Re- submittal Comments
Ms. Burgmaier,
Seneca Coal Company
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Seneca Coal Company (SCC) has reviewed the DRMS Adequacy letter of March 16, 2011 and is
submitting this package to address the concerns about aspen/woody plant density standards. Responses to
the items of concern are presented below.
1. Page 57 — In the currently approved restoration plan, the overall woody plant density standard for
concentrated planting areas is 2,000 stems /acre. This standard was determined at the time of the
original permit without understanding the difficulty of getting shrubs established. The Revegetation
Monitoring Reports of 2007, 2008 and 2009 indicate that shrub establishment areas have had a
moderate amount of success creating shrub habitat. It is clear that 2,000 stems /acre will prove to be
a difficult goal even with the latest shrub technology. Some areas have far exceeded expectations with
densities greater than 13,000 stems /acre while many areas have not achieved 1,000 stems /acre after
two to four growing seasons. According to the 2008 Revegetation Monitoring Report, the area -
weighted average of all shrub concentration areas is just under 1, 700 stems /acre. Given these results,
the Division agrees with the five woody plant density standards proposed by Seneca Coal Company
with the following exceptions:
a. The secondary standard no. 1 — 10% of the unfenced, shrub concentration areas have at least
1,000 shrubs per acre should be a mandatory standard.
b. The woody stem average of 850 stems /acre in standards 2 -4 should be increased to 945
stems /acre. This increase in stem density count will account for the allowable density of 90% of
approved statistical average standard stated in Tab 22, page 46, paragraph 1. This makes the
minimum possible allowable stem density to be 850 stems /acre.
Response: Page 57 has been revised to indicate that as a Mandatory Shrub Standard - 10% of the
unfenced, shrub concentration areas must have at least 1,000 shrubs per acre and the woody stem average
has been increased to 945 stems /acre.
Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639
Telephone [phone] • FAX [phone]