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20% Portal Reference Areas (10% Original Reference Area 1 and 10% New Reference Area 2) and the <br />remainder in the Refuse Pile Reference Area. To change the revegetation standards would be arbitrary at <br />this phase of the revegetation. DRMS should not change the standards but be required to meet the <br />standards. <br />We support TR 42 to convert pond 4 to permanent status. These will help us provide for the wildlife that <br />use the property and supports the reclamation plan. <br />We do not agree that EFCI should be allowed to wait until near the end of the reclamation to close all of the <br />bore holes or the wells. These should be found and closed immediately. <br />We expect DRMS to uphold their responsibility of upholding the standards of the revegetation program. <br />EFCI needs to reseed and replant with one gallon shrubs, staked on 3 sides to protect them from wildlife <br />and to water as needed for their survival for the coming five years. Since they would be planting larger <br />specimens of shrubs, the length of time is shortened. Since EFCI has not modified their revegetation plan <br />that is part of their reclamation plan to meet the standards in the 10 years that were allocated, the <br />landowners expect to negotiate a reasonable fee for still not having their land reclaimed and able to be <br />utilized for the coming five years. To supplement the watering program, EFCI could utilize the wells that <br />the landowners are requesting that EFCI dig and make functional before any bond release is considered, <br />We will ask that the DRMS enforce the revegetation standards in the regulations and not allow EFCI to <br />rewrite them or come up with their own percentages and averages so that they are guaranteed to meet <br />them. EFCI's changing the standards is arbitrary and capricious especially at this point of revegetation and <br />reclamation. We hope that you will deny this TR 45 in your staff recommendation in April. <br />Sincerely, <br />Tena Gallagher, representing Linda Saunders, Ted Coulter and Paula Coulter <br />