2014-06-17_REVISION - C1981014 - Laserfiche WebLink

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15. Please bring the discussion on page 2.05.4 -27 in the PAP document into agreement with pages 2.04.10 -5 and 5a with respect to the weighted average approach discussion. This should include the "new portal reference area." Response: The current sentence found in the first partial paragraph on page 2.05.4 -27 which reads "Reference area data for the grassland (Reference Plot A) and ponderosa/pinon/juniper woodland (Reference Plot B) will be combined using a weighted average approach ", Will be revised to read: "Reference area data for the grassland or Refuse Pile Reference Area (Reference Plot A); and ponderosa/pinon/juniper woodland (Old Portal Reference Area or Plot B); and the new Portal Reference Areas will be combined using a weighted average approach described on revised pages 2.04 -10 -5, 2.04.10 -5a and 2.04.10 -5b." The current sentence in this same paragraph which currently reads: "Consistent with the pre - disturbance vegetation boundaries, and disturbed area mapping, the weighting factor will reflect 79.8 percent for the grassland and 20.2 percent for the ponderosa/pinion /juniper woodland disturbed," Will be revised to read: "Consistent with the pre - disturbance vegetation boundaries, and disturbed area mapping, the weighting factors for the reclaimed areas at the Southfield Mine will be 79.8 percent for the grassland or Refuse Pile reclamation and 20.2 percent for the pinion/juniper woodland type, corresponding to the Vento Portal and Corley reclamation areas, located on the old surface facilities area. Based upon detailed measurements taken of these reclaimed areas in the fall of 2013, the 20.2 percent factor for the mine facilities area will be subdivided as follows: The weighting factor for the Vento Portal reclamation area will be 9.42 percent and the weighting factor for the Corley Reclamation area will be 10.78 percent. The contribution from the Refuse Pile, Vento Portal and Corley reclamation areas, will then be summed into the composite final revegetation weighted average value to represent the reclaimed areas at the Southfield Mine area, similar to the approach outlined for the three reference areas described on Permit pages 2.04.10 -4, 2.04.10 -5 and 2.04.10 -5a." Revised page 2.05.4 -27 attached. 16. Page 2.05.4 -27a in the PAP requires more clarification regarding measurement of woody plant densities and delineation of shrub clumps. An acceptable way to clarify which area is defined as a shrub clump versus seeded area would be to reference a specific map (e.g., a map in an Annual Reclamation Report). Response: In connection with the Phase III Final Bond Release Monitoring, performed in September 2013, EFCI's vegetation consultant, met with Ms. Janet Binns and Mr. Rob Zuber in the field to refine concerns over the sampling of shrub densities on all reclaimed areas as well as appropriate delineation of those areas where shrub clumps exist. As a part of that intensive field sampling effort, investigations were made to identify the boundaries of every shrub clump identified in the 2004 Annual Reclamation Report as being planted by the Colorado State Forest Service. The boundaries of every shrub clump were flagged in the field with either plastic pin flags or flagging and these boundaries were then GPSed with a GPS unit. The results from this investigation have been prepared into a single map, showing the location of every Shrub Clump, its number and area, which have been inserted into the 2013 Phase III Revegetation Sampling Report. A copy of this map will be submitted in connection with these responses. Enclosed maps (2): Refuse Pile Shrub Clumps Map Vento Portal Reclamation Shrub Clump Map