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For the Division to maintain consistency, the following two species of woody plants which have <br />been so consistently documented in the scientific literature as possessing either "poisonous" <br />"allelopathic" "phytotoxic" or "inhibitory" substances to such a degree that the desirable plants <br />required to achieve the desired post- mining land uses or rangeland or grazing land and wildlife <br />habitat cannot be expected to grow satisfactorily; including One -seed Juniper and Pinyon Pine, <br />must be excluded from the reclamation plan at the Southfield Mine <br />Accordingly, the proposed woody plant density standard for the Southfield Mine area based upon <br />the contribution of the "nonpoisonous" woody plants and trees encountered on this site, will <br />consist of the contributions of Skunkbush sumac (Rhus trilobata), Snowberry (Symphoricarpos <br />rotundifolius), Singleleaf ash (Fraxinus anomala), Rubber Rabbitbrush (Chrysothamnus <br />nauseosus), Hoptree (Ptelea trifoliata), Virgins Blower (Clematis columbiana), Douglas <br />Rabbitbrush (Chrysothamnus viscidiflorus) and Big Sagebrush (Artemesia tridentata). These <br />eight plants produced an average of 2.74 woody plants per 100 square meters. Thus, the final <br />proposed woody plant density standard at the Southfield Mine would be 90 percent of 110 <br />woody plants per acre or 100 woody plants per acre. <br />Concern # 5. On proposed page 2.05 -4 -27, it is unclear how EFCI plans to apply the <br />weighting factor for the portal area Vento land ownership and Corley land ownership. It <br />has previously been approved that the Portal disturbance area accounted for 20.2 % of the <br />mine disturbance. The Portal disturbance area correlates to the woodland pre- mining <br />vegetative community. EFCI proposes that the Vento portal reclamation will be weighted <br />9.42 percent and the Corley portal reclamation will be weighted 0.78 percent. <br />Page 5 of EFCI's explanation of the proposed changes defines the Vento portal area was <br />surveyed at approximately 10.22 acres, and the Corley portal area was surveyed as <br />approximately 11.71 acres. The Division calculates that the Vento property would account <br />for 46.6 % of the Portal area, and the Corley property would account for 54.4 percent of <br />the Portal Area. <br />Please provide an explanation of how the 9.42 % and 0.78 % acreage ratios were <br />determined. <br />Response: EFCI is unable to find the 0.78 percent figure on this page and thus cannot comment <br />on this number as it appears to be in error. The Division is correct in that the currently approved <br />Southfield Mine Permit says that the weighting average values for the Grassland (Refuse Pile) <br />Reclaimed will be 79.2 percent and that the weighting factor for the woodland type (Portal <br />Reclamation) will be 20.2 percent. Based upon the GPSed areas of the Vento Portal <br />Reclamation and Corley Reclamation portion of woodland disturbance at the Southfield Mine <br />Portal completed in 2013, the respective areas of these two reclaimed areas, were as is reported <br />by the Division to be 10.22 and 11.71 acres, respectively. The Division's calculations of the <br />Vento Portal Reclamation accounting for 46.6 percent and the Corley property accounting for <br />54.4 percent of the portal reclamation are correct. Application of these percentages to the <br />currently approved 20.2 percent weighting factor for the premining woody vegetation type <br />15 <br />