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would be a site wide woody plant density of 400 stems per acre also requires successful <br />establishment of 1.5 acre concentrated transplanted shrub clumps within every 46 acre <br />area of influence. <br />Please consider a woody plant density success standard that promotes both of the <br />approved post -mining land uses for the site, rangeland and wildlife habitat. (Rule <br />4.15.1(1) <br />4. On proposed page 2.05.4-27, it is unclear how EFCI plans to apply the weighting factor <br />for the portal area Vento land ownership and Corley land ownership. It has previously <br />been approved that the Portal disturbance area accounted for 20.2% of the mine <br />disturbance. The Portal disturbance area correlates to the woodland pre -mining <br />vegetation community. EFCI proposes that the Vento portal reclamation will be <br />weighted 9.42% and the Corley portal reclamation will be weighted 0.78%. <br />Page 5 of EFCI's explanation of proposed changes defines the Vento portal area was <br />surveyed as 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 <br />account for 46.6% of the Portal area, and the Corley property would account for 54.4% <br />of the Portal area. <br />Please provide an explanation of how the 9.42% and 0.78% acreage ratios were <br />determined. <br />EFCI response states that, "EFCI is unable to find the 0.78 percent figure on this page <br />and thus cannot comment on this number as it appears in error." <br />The Division concurs that this figure may indeed be a typo on revised page 2.05.4-27 <br />(Rivised [sic] 01115). The second paragraph of this revised page states, <br />The weighting factor for the Vento Portal reclaimed area will be 9.42 <br />percent and the weighting factor for the Corley reclaimed area will be <br />0.78 percent. The contribution from the Refuse Pile, Vento Portal and <br />Corley reclaimed areas will then be summed into the composite final <br />revegetation weighted average value to represent the reclaimed areas at the <br />Southfield mine, similar to the approach outlined for the three reference <br />areas described on pages 2.04.10-4, 2.04.10-5 and 2.04.10-5a. <br />EFCI's May 12, 2015 response provided an acceptable explanation of how the reclaimed <br />area weighting factors will be applied. In the PAR response letter, EFCI stated that the <br />Vento Portal reclamation will have a proportional weighing factor of 9.41 percent and the <br />Corley property will have a proportional weighting factor of 10.99 percent. These two <br />values total to the 20.2 percent previously calculated for the woodland vegetation type. <br />EFCI's explanation is acceptable; however EFCI did not provide a corrected page 2.05.4- <br />27. Please submit a revised page 2.05.4-27 that corrects the ratio allotted to the Corley <br />portal area reclamation. <br />