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<br />Page 5 <br />Letter to Carol Pahlke <br />January 2, 1981 <br />Response: An explanation supporting the sample ade- <br />quacy with respect to the subject population parameter <br />estimates is provided at revised pages 779-72bbbbb, <br />779-72ccccc and new Figure 38. <br />Revised Pages: Revised pages 779-72bbbbb and 779-72 <br />ccccc and new Figure 38, Shrub Density - Frequency <br />Distribution Treated Sagebrush Vegetation Type, have <br />been attached hereto. <br />5. Kerr's proposal to establish shrubs at a rate of 2000 <br />stems/acre has been reviewed by the staff and found to be not <br />acceptable based on the information cited. Beck (1975 pg. 45) <br />indicates that the major distribution of sage grouse is in NE <br />North Park and that if mining proceeds, careful provisions should <br />be made to preserve critical winter habitat, by conserving sage- <br />brush. Kerr will need to accept the reference area data with <br />respect to suitable shrub density levels or propose a suitable <br />standard. <br />Response: In a meeting between MLRD representatives <br />and representatives of Kerr Coal on December 31, 1980, <br />it was agreed that MLRD would stipulate that Kerr <br />Coal and the regulatory authorities would agree upon a <br />success standard for woody plant density on or before <br />September 30, 1981. <br />6. Kerr needs to submit a plan for monitoring revegetation <br />success (with special regard to dominance of introduced species) <br />of reclamation efforts at the Kerr Mine. <br />Response: Kerr Coal has previously proposed a plan <br />for monitoring revegetation success of reclamation <br />efforts. This proposal is reflected on page 5 of the <br />December 23, 1980 Kerr Coal response to the December <br />5, 1980 MLRD adequacy letter. The proposal is fur- <br />ther documented in revised pages 816-161aaaa and 816- <br />161bbbb. <br />D. Proof of Publication. <br />Response: At the request of MLRD, Kerr Coal has <br />enclosed with this letter a copy of the Proof of <br />Publication with respect to the submission of its <br />permit application and mine plan. <br />