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The acreage values of the approved reference areas must stay consistent. Please <br />continue to use consistent acreage values as approved. If a correction to the surveyed <br />acreage is necessary, then the respective pages, with an explanation of the need for the <br />correction is required. <br />EFCI provided corrected acreages based upon surveyed area for reference areas at the <br />Southfield mine site. <br />Grassland reference area 2.80 acres 58.6% <br />PPJ (Plot B -Portal area) 0.29 acres 6.0% <br />New Portal Area Reference area (PJ) 1.69 acres 3.54% <br />4.78 acres <br />The Division accepts these revised acre values. Please submit a revised page 2.04.10-5b <br />to correct these surveyed values in the permit. <br />2. EFCI is proposing a change to the diversity standard based upon the relative acreage of <br />the four reference areas, including the New load out reference area 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 on approved <br />permit pages 2.04.10-5 through 5b. <br />Please provide justification for using the relative acreage of the four reference area for <br />an individual success standard. <br />EFCI noted that the currently approved warm season standard is a permit wide standard. <br />Calculating the warm season requirement based on all four reference areas is in <br />agreement the intent of the currently approved warm season standard. <br />EFCI has yet to submit vegetation sampling reports from vegetation sampling efforts <br />conducted in 2013 and 2014. Submittal of the 2013 and 2014 vegetation sampling <br />reports would assist the Division in evaluating the proposed changes. <br />The operator calculated the warm season component of the 2013 data for the reference <br />areas using the currently approved diversity standard. For the 2013 sampling of the <br />reference areas, the two dominant warm season grasses contributed 44.36% relative <br />cover. The undisturbed reference areas were unable to meet the currently approved <br />warm -season grass diversity standard for the 2013 data. <br />The operator calculated the warm season component of the 2014 data for the reference <br />areas using the currently approved diversity standard. For the 2014 sampling of the <br />reference areas, the two dominant warm season grasses contributed 38.6% relative cover. <br />The undisturbed reference areas were unable to meet the currently approved warm -season <br />grass diversity standard for the 2014 data. <br />The proposed change to the method used to calculate warm season species reclamation <br />success is consistent with Rule 4.15.7(4)(b). This revision to the warm season success <br />standard provides for an applicable warm season grass component that is supported by <br />