2013-11-18_REVISION - C1981014 - Laserfiche WebLink

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Pinyon /Juniper reference area (Proposed reference area) =Z acres So the weighted reference area standard would equal.• Plot A Mean * X acres / (X +Y +Z) acres +Plot B Mean * Y acres / (X +Y +Z) acres+ Proposed Ref. Area Mean * Z acres / (X +Y +Z) acres. This weighted reference area standard would then be used for the success comparison for the weighted reclamation blocks. The submitted November 2013 pages have been formatted so that they fit into previously approved permit text without loss or duplication of text. (Item No. 2). This concern has been addressed. Item No. 3: A revised map showing the proposed reference area with previously disturbed area (Black Hawk Mine disturbance) was provided on 11/12/2013 (Item No. 3). EFCI submitted two revised maps; Map 16, dated 10/13. I digitized the scale of this map, and attempted to digitize the "New Mine Portal Reference Area" (Previously referred to in TR39 proceedings as "proposed Pinyon Juniper reference area "). The scale of the revised map 16 (10/13) is in error. Comparison with the previously approved Map 16 indicates that the scales are in disagreement. Revised Map 16 (10/13) scale needs to be corrected. The Revised Map 16 (10/13) appropriately eliminated portions of the previously proposed "New Mine Portal Reference Area" to remove areas identified as having been previously disturbed by historic mining. This portion of the response is acceptable. The previously approved Plot B reference area shown on revised Map 16 (10/13) has been changed in size and shape. This change appears to reduce an already small approved reference area. During an inspection on 8/20/2013, using my Yuma GPS unit, I attempted to walk the perimeter of Plot B reference area. I was unable to locate all of the corner posts but walked as closely as the terrain and vegetation allowed to the perimeter downloaded from the approved Map 16. 1 did not observe any reason to reduce this small reference area further than it already is. EFCI should maintain the boundary definitions as previously depicted. Item 4: Map 1 "Southfield Mine Reclamation Map" (10/30/2013) scaling seems off as well. I digitized the scale (with Rob's assistance) and digitized the "New Mine Portal Reference Area ". I consistently digitized this area as 2.1 acres. EFCI reports the area as 1.68 acres. This results in a 25% error between DRMS measurement and EFCI's measurement. For the sake of accuracy on such a small reference area, I would ask that EFCI double check the scale. The currently approved "Map 1" in the Southfield permit is "Mine Area Surface and Mineral Ownership ". The revised "Map 1 Southfield Mine Reclamation Map" (10/30/2013) should be given a unique name to minimize confusion (illustration 1, or figure 1 do not appear to have been used previously). The shape of Plot B also appears to be changed on this map. Once these details are cleared up, I believe that the revision should be in agreement with the regulations, guidelines, and be clear as to the definition of the reference areas, and how the reference areas will be used for reclamation success comparison.