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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. <br />12. Section 2.05.2 of the PAP should be revised to reflect the current status of <br />activities on the mine site. For example, the text in this section indicates that <br />Southfield is still producing coal. <br />Revised pgs: <br />2.05 -1 <br />2.05 -1 a <br />13. Section 2.05.3 of the PAP should be revised to reflect the current status of <br />the ponds. Pond 1, Pond 2, and Pond 3 have been reclaimed, but this is not <br />discussed in the text. It would also be useful to add a discussion in this section <br />concerning which ponds are planned as permanent. <br />Revised pgs: <br />2.05.3 -44 <br />2.05.3 -45 <br />2.05.3 -45a <br />14. Table 33 in Section 2.05.4 of the PAP (and related Tables 33A and 33B if <br />necessary) should be revised to confirm the most recently approved seed mixes and <br />to document the revision and date of the latest versions. For example, Table 33 needs to <br />reflect the latest revision; it has been updated more recently than March 2003 with <br />MR -48. <br />Response: Table 33 corresponds to MR -49 of March, 2003. (Note that Footnote 2 <br />in Table 33 indicates that Fourwing Saltbush is eliminated when pertaining to the <br />Corley property). <br />Attached revised page(s): <br />2.05.4 -21 <br />