2011-08-02_REVISION - C1994082

• Permit No: C1994082
• 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: TR48
• Email Name: SLB
• Email Name: SB1
• Media Type: D
• Archive: No

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,S ENECA
Coal Company
August 30, 2011
Ms. Susan Burgmaier
Division of Reclamation, Mining and Safety
1313 Sherman, Room 215
Denver, CO 80203
RE: Yoast Mine Permit No. C -94 -082
Technical Revision (TR -48) - Aspen/Woody Plant Density Standard
Response to Re- submittal Comments
Ms. Burgmaier,
Seneca Coal Company
r∎u O t 2011
+fi
pivi n of ley
Ili TIM end
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 47- In the currently approved restoration plan, the overall woody plant 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 I 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 4,000 stems /acre while many
areas have not achieved 1,000 stems /acre after three to five growing seasons. According to
the 2008 Revegetation Monitoring Report, the area - weighted average of all shrub
concentration areas is just under 1700 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 49, paragraph 3.
This makes the minimum possible allowable stem density to be 850 stems /acre.
Response: Page 47 and 48 have been revised to indicate a Mandatory Shrub Standard - 10% of
the unfenced, shrub concentration areas 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]