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Northfield Permit Application <br />Preliminary Adequacy Review <br />Vegetatiou Information -Rule 2.04.10 <br />November 9, 2006 <br />Rule 2.04.10 (1) requires a vegetation map, prepared in accordance with Rule 2.10, which <br />delineates the plant communities with the azea to be affected by surface activities for <br />underground mines. NP provided Map 3 which shows a proposed disturbance azea and a <br />proposed reference azea. The proposed ,'disturbance area is different from what is <br />discussed and delineated elsewhere in the permit. The map must show the correct <br />disturbed azea. Additionally, the map does not contain identifying geographic location <br />information such as township, range, or section. These features must be on the map. <br />8. A description of the plant communities for the proposed disturbed azea was provided in <br />Exhibit J. The report in Exhibit J was completed during the summer of 1991. Baseline <br />data for cover, production, woody plant density and species composition was collected <br />from the proposed disturbed azea shown on Map 3. As stated above, the disturbed area <br />has changed. Baseline data for the current proposed disturbed area must be provided. <br />This includes vegetative cover, production, species composition and woody plant density. <br />NP will also need to collect data from the proposed reference azea at the same time data <br />is collected from the correct disturbed area to ensure the two areas will be compazable as <br />required by Rule 4.15.7(3). <br />The methods used to collect data for the report in Exhibit J are generally con•ect. <br />However, the Rules and Regulations for Coal Mining (Rules) were updated in September <br />2005 and most of the revisions pertained to the revegetation sections of the Rules. Rule <br />4.15.11 was added which describes the vegetation sampling methods for all aspects of the <br />vegetation sampling program, including baseline data collection. The cover data for the <br />Northfield Mine was collected using a plum bob on a 4 foot string at each meter mark <br />along a 50-foot transect. Please note that newly added Rule 4.15.11(1)(a) requires that a <br />point sampling device supported by a rigid frame be utilized to ensure unbiased point <br />placement. <br />9. In Exhibit J NP proposes to use a reference azea to demonstrate revegetation success. NP <br />provides a statistical demonstration showing the proposed disturbed area and the <br />reference area is comparable. The statistical formula shown on page 12 should be <br />corrected. It is the square root of the denominator. (I did not review the calculations to <br />determine if they were done properly, since the disturbed area sampled is incorrect.) The <br />calculations will need to be redone when data from the correct disturbed azea is collected. <br />Rule 2.04.10(5) and Rule 2.04.11(4) <br />10. The United States Fish and Wildlife Service threatened and endangered species list for <br />Fremont County is shown below. <br />Arkansas Darter Etheos[oma cragini C <br />Bald Eagle Haliaeetus leucocephalus T <br />Black-footed Ferret Mustela nigripes E <br />