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Grassland reference area2.80 acres58.6% <br />PPJ (Plot B-Portal area)0.29 acres6.0% <br />New Portal Area Reference area (PJ)1.69 acres3.54% <br />Total reference area acres4.78acres <br />The New Load out reference area was approved as 1.02 acres(TR41, approved <br />November 6, 2014, page 2.04.10-5b).Approved permit pages 2.04.10-5 through 2.04.10- <br />5bdefinethat the mine area referencearea data will be combined based on acreage <br />weighted values, while the load out reference area will be used only for comparisonto the <br />reclaimed load out. The New load out referencearea should not be includedwith the <br />acreage weighting of the mine area reference area. <br />The acreage values of the approved reference areas must stay consistent. Please continue <br />to use consistent acreage values as approved.If a correction to the surveyed acreage is <br />necessary, then the respective pages, with an explanation of the need for the correction is <br />required. <br />2.Comparison of cover and productivity, and woody plant density is based upon the relative <br />areas that each plant community was projected to occupy prior to mining disturbancefor <br />reclaimed areas at the mine area in accordance withRule 4.15.7(4)(b). <br />EFCI is approved to compare reclamation success standards for the load out to the New <br />load out reference area (TR41, approved November 6, 2014, page 2.04.10-5b). <br />In accordance with approved permit page 2.04.10-5and 5a,revegetation success <br />standard for plant cover and forage production will be calculated based upon the <br />surveyed areas of the three respective reference areas; Refuse Pile reference area, the <br />New Portal reference area, and the Old Mine Portal reference area. <br />EFCI is proposing a change to the diversity standard based upon the relative acreage of <br />the four reference areas, including theNew load out referencearea values with the three <br />mine site reference areas.This proposed change is inconsistent with the methods for <br />determining reclamation success for cover and forage productivity as stated onapproved <br />permitpages2.04.10-5through5b. <br />Please provide justification forusing the relative acreage of the fourreference area for an <br />individualsuccess standard. <br />3.The approved post mining land use is rangeland and wildlife habitat. The operatoris <br />responsible for establishing apost-mining vegetation community that supports both land <br />uses. The Colorado Division of Wildlife (aka Colorado Parks and Wildlife)provided <br />recommendations in 2002 regarding management of the wildlife habitat.However,the <br />reclaimedproperty is privately owned and some of the landowners have expressed <br />interest in reestablishment of trees and shrubs as well as domestic grazing. EFCI planted <br />One-seeded juniper seedlings, in addition to otherapprovedtree and shrub species,on the <br />