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• Division of Wildlife Issues and Responses <br />for June 5, 1997 Letter <br />(continued) <br />Techniques used to establish shrubs aze also critical to reclamation success. The Division's <br />experience indicates that including shrubs in the seed mix as the only technique to establish shrubs <br />is marginal, at best, in achieving shrubs on reclaimed areas. Favorable techniques to consider <br />include: <br />* test plots to optimize techniques; <br />* strip seeding along contour or on terraces; <br />* live handing of topsoil in isolated azea; and <br />* mature transplants in limited numbers. <br />Determining the success of these efforts is important when release of the lands from liability is <br />requested. Factors to consider when determining shrub density and viability include: <br />* permanent transects; <br />* numerical standards; and <br />* performance-based standards. <br />The Division would like the applicant to consider these factors with the goal of crafting a <br />• revegetation plan that includes re-establishing shrubs. We are interested in working cooperatively <br />with you and value input you have with regard to this issue. Please provide comments and <br />concerns, or if you choose, provide a specific plan for our review. At this time, this issue remains <br />outstanding. <br />Response <br />As requested in the response to the May 27, 1997 adequacy letter, LCC would like additional time <br />to research and assemble the revegetation plan for the surface mine area that would contain shrubs. <br />LCC has made the commitment to establish shrubs in areas of the surface mine, however, methods <br />of establishment and success standards still need to be determined. LCC has requested a <br />stipulation on the permit for the submittal and approval of this plan. <br />Rule 3.02.2 Reclamation Cost Estimate <br />The Division is currently completing review of the reclamation cost estimate information. <br />We anticipate being able to identify any remaining issues by June 13, 1997. <br />Response <br />No response is necessary for this comment. <br /> <br />This concludes LCC's response to this adequacy letter. <br />