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Page 4 <br />Letter to Carol Pahlke <br />January 2, 1981 <br />Revised Paces: Revised pages 816-156a and 816-156b <br />ave been attached hereto. <br />2. References to page 780-15 on revised pages 816-118aaa, <br />and 816-118bbb should be changed to page 785-15. The referred <br />page addresses the seven riparian species to be transplanted by <br />Kerr. <br />MLR requests that Kerr elaborate briefly on the method by <br />which Kerr proposes to transplant the riparian species mentioned <br />on pages 785-15, 816-118aaa and 816-118bbb. <br />Response: MLRD has correctly noted that the refer- <br />ences on page 816-118aaa and 816-118bbb should be <br />to page 785-15 rather than 780-15. Kerr Coal accord- <br />ingly requests that MLRD and OSM make the necessary <br />interlineated changes on copies of the application in <br />their possession in order to reflect the proper page <br />references. <br />Transplanting of riparian species identi- <br />fied on pages 785-15, 816-118aaa and 816-118bbb will <br />be accomplished by using sound management techniques <br />which conserve the plant material associated with <br />these species in a moist condition. These techniques <br />will be employed during the acquisition, transporta- <br />tion and planning process. <br />3. Kerr's response to the Division's queries on stubble mulch <br />success are not adequate. Kerr should either accept the criteria <br />set forth by MLR in the November 6, 1980 letter or else Kerr must <br />propose a set of success criteria which are backed by sufficient <br />technical literature, and are appliccable in this case. <br />Response: In a meeting between representatives of <br />Kerr Coal and MLRD on December 31, 1980, it was <br />agreed that the proposed success standard for stub- <br />ble mulch set forth in previously submitted revised <br />page 780-73aaa was adequate and acceptable. <br />4. Kerr's response to the Division's questions regarding sam- <br />ple adequacy for the parameters of density and intercept for treated <br />sagebrush have clarified the situation with regard to the high <br />variability of this vegetation type. However, Kerr must demonstrate <br />that their sampling is adequate to reflect the nature of this given <br />vegetative community before the Division is satisfied with popula- <br />tion parameter estimates which do not meet specified statistical <br />criteria. <br />