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E <br />S c~+c~.n,. Seneca Coai Company <br />October 19, 2006 <br />Mr. Mike Boulay <br />Division of Redunadon, Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />(303) 866-3567 <br />RE: Yoast Mine Permit No. G94-082 <br />2005 Amual Reclamation Report <br />Response to Comments <br />Deaz Mr. Boulay, <br />REGE9VED <br />OCT L 0 2006 <br />Division of Reclamation, <br />Mining and Safety <br />Seneca Coal Company (SCC) has reviewed your 2005 Annual Reclatttation Report Review letter, dated 9/11/06, and <br />has formulated the following responses to the comments. <br />1. The acreage valuer in the Report Form submitted by SCC with the 2005 ARR are not ronrirtent with the valuer from the 2004 <br />report An explanation has been provided for the diffennrer in total acreage dirturbe~ but the other reported acnager that appear to be <br />in error. Please review the items krted below andprovide a corrected report form for the 2005 ARR Dircrepaneier include: <br />a The cumulative total of backfilled andgraded acres reported in the 2004 ARR it 391.3 acres. The 2005 npori indicates that an <br />additiona1119.4 acre wen backfilled and regraded during 2005, for a total of451.5 serer. Assuming lartyear s cumulative <br />amage war correct, thiryear'r total should be 510.7. <br />The cumulative total of topsoiled acres reported in the 2004 ARA it 315.5 acres. The 2005 report indicates that an additional <br />115.1 acres were topsoikd during 2005, for a total of 472.9 acres. Assuming fart years cumulative acreage war coma, this <br />year's total should be 430.6. <br />c. The seeded acreage values nporYed an also inronrirtent. The 2005 report states that lartyear'r cumulative total war 308.2 acres. <br />The actua12004 re/wned fatal war 296.2 which, when added to the 2005 acreage of 96.6 acres, should tats! 392.8. The 2005 <br />report has a new cumulative total of 404.8 acres. <br />Response: As you coaecdy noted, the total azea of disturbance was revised to match current conditions. However, <br />the cover/transmittal letter also states... `°I'he Yoast Mine area was reviewed and revised to accurately portray the <br />categories of activities...." This statement refers to all categories -disturbed, backfilled and graded, topsoiled, and <br />seeded. <br />Based on the most recent aerial photography available, physical surveying, and remapping; the acreages were reconciled <br />to match cuuent on-the-ground configurations. With this in mind, SCC will leave the acreages reported on the form as <br />submitted. <br />2. The text, on page 3, stater that revegetated areas wen seeded with Seed Mix #fA (Merit Anar/Ephemeral Drainages), but the reed <br />tags provided don't fully support tbir statement. Seed tags provided document four mixer; Connntrated Shrub Seeding Areas, Upland <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81838 <br />Telephone (970) 2783707 • FAX (970) 2763014 <br />