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10. The grassland reference area for the loadout has apparently been damaged by other <br />parties. EFCI needs to establish a replacement reference area or propose acceptable <br />reclamation success standards for the loadout and update applicable text in Section 2.04.10 <br />in the PAP. EFCI may want to consider using the approved grassland reference area <br />included in the Southfield permit. <br />Response: EFCI has submitted Technical Revision No. 41 (TR -41) request addressing this <br />issue. Approval by the Division of the TR request is pending. <br />11. Per Rule 2.04.10(5) EFCI needs to verify that the current State and Federal <br />Threatened and Endangered species list are included in the Southfield Mine Permit. <br />Response: An Endangered Species list is included in the permit, however, EFCI adds the <br />following comment: According to Rule 2.04.10(5) the potential impacts "to rare and endangered <br />plant species shall be evaluated ... " and Rule 2.07.6(2)(n) which require that activities "not <br />affect the continued existence of endangered and threatened species or result in the destruction of <br />adverse modification of critical habitats ... " Rule 2.05.6(2)(a)(iii) says that "threatened or <br />endangered species of plants" are to be protected "if they are to be affected by the proposed <br />activities ... " There will be no additional impacts beyond what has already been approved to be <br />disturbed as a result of this Permit Renewal. All of the disturbance at this mine site has already <br />occurred. There have been no concerns relative to threatened or endangered plants for the past <br />34 years and there is no absolute reason why EFCI needs to "verify that the current State and <br />Federal species list are included in the Southfield Mine Permit." <br />12. To be addressed under separate cover at a later date. <br />13. To be addressed under separate cover at a later date. <br />14. To be addressed under separate cover at a later date. <br />15. Please bring the discussion on page 2.05.4 -27 in the PAP document into agreement <br />with pages 2.04.10 -5 and 5a with respect to the weighted average approach discussion. <br />This should include the "new portal reference area." <br />Response: The current sentence found in the first partial paragraph on page 20.5.4 -27 which <br />reads "Reference area data for the grassland (Reference Plot A) and ponderosa/pinon /juniper <br />woodland (Reference Plot B) will be combined using a weighted average approach ", Will be <br />revised to read: "Reference area data for the grassland or Refuse Pile Reference Area (Reference <br />Plot A); and ponderosa/pinon/juniper woodland (Old Portal Reference Area or Plot B); and the <br />new Portal Reference Areas will be combined using a weighted average approach described on <br />revised pages 2.04 -10 -5, 2.04.10 -5a and 2.04.10 -5b." <br />The current sentence in this same paragraph which currently reads: "Consistent with the pre - <br />disturbance vegetation boundaries, and disturbed area mapping, the weighting factor will reflect <br />79.8 percent for the grassland and 20.2 percent for the ponderosa/pinion /juniper woodland <br />disturbed," Will be revised to read: "Consistent with the pre - disturbance vegetation boundaries, <br />and disturbed area mapping, the weighting factors for the reclaimed areas at the Southfield Mine <br />will be 79.8 percent for the grassland or Refuse Pile reclamation and 20.2 percent for the <br />pinion/juniper woodland type, corresponding to the Vento Portal and Corley reclamation areas, <br />