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INTEROFFICE MEMORANDUM <br />TO: JASON MUSICK <br />FROM: JANET BINNS <br />SUBJECT: SENECA II MINE, C1980-005, TR52 <br />DATE: 8/1/2012 <br />CC: <br />I have reviewed Seneca Coal Company’s (SCC) application for a reduction in area of the <br />approved Sagebrush Reference Area. SCC has monitored the current 8 acre Sagebrush <br />reference area since 1979. The Sagebrush Reference Area is used for reclamation <br />success comparison for the Seneca II Mine. Future plans for the adjacent Peabody Sage <br />Creek Mine anticipate that a portion of the Sagebrush Reference Area will be disturbed <br />by conveyor and associated road. <br />SCC proposes to reduce the size of the Sagebrush reference area to 4 acres. The <br />undisturbed portion of the Sagebrush Reference Area will be the eastern half. SCC has a <br />long record of monitoring the reference area. The Division evaluated the results of <br />Annual Vegetation reports for the Seneca II Mine for 2006, 2007, 2008, 2009, 2010, and <br />2011. Vegetative Cover values were compared for the 8 acre reference area to data <br />associated with proposed reference area. In all years evaluated, with the exception of <br />2007, the cover values of the proposed reference area were slightly higher than for the <br />historic 8 acre reference area. A T-test calculations graph provided by SCC found that <br />there was no statistically significant difference between the cover values of the proposed <br />reference area and the existing reference area. <br />The Division evaluated the results of productivity sample values for the Seneca II Mine <br />for 2006, 2007, 2008, and 2011. Production data was not collected in 2009 and 2010. <br />Vegetative Cover values were compared for the 8 acre reference area to data associated <br />with proposed reference area. A T-test calculations graph provided by SCC found that <br />there was no statistically significant difference between the herbaceous productivity <br />values of the proposed reference area and the existing reference area. 2006 data resulted <br />in a noticeably lower productivity value for the reduced reference area than for the 8 acre <br />reference area. This difference was not noticeable is subsequent sampling events (2007, <br />2008 and 2012). <br />One item of concern: <br /> <br /> <br />The revised permit page 13-28, provided by SCC, states that, “sampling was not <br />conducted for production in 2009 and 2011.” The Division believes that <br /> <br />