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remaining 156 (evenly divided among the three species) were planted <br />outside of the northwest corner of the study plot (see Attachment 1 to <br />this comment). <br />PCC does not consider the above study area and study design to be an <br />experimental practice, but will use the area to document whether this <br />practice is a highly viable method of shrub establishment for the Seneca <br />Mine site in particular. The study plot will also aid in identifying <br />any necessary changes or improvements needed prior to these practices <br />being implemented on a larger scale. As stated in the response to <br />Comment 9 of the PAR, plot size for any nonseeded areas will remain at <br />one acre or less. These nonseeded areas will be designated for maximum <br />shrub establishment, survival and growth. Designating an area that is <br />dedicated for maximum shrub establishment, and hence highest woody plant <br />densities, is consistent with PCC's objective of establishing islands or <br />groupings of shrubs for cover habitat. This is also a cost and manpower <br />effective means of providing an adequately sized shrub establishment <br />area. An added benefit of reduced herbaceous competition will be <br />increased survival and growth of regenerating native species contained <br />in live handled topsoil. <br />PCC acknowledges the concern for potential erosion on the unseeded plot. <br />However, the potential for erosion will be minimized for the following <br />reasons. The approximate one-acre size of the plat is small in relation <br />to the reclaimed area as a whole. The reclaimed areas surrounding the <br />nonseeded plot will be seeded with a cover crop or mulched and seeded <br />with the permanent seed mix. This will result in stabilization of the <br />surrounding contributing area and control of run-on to the plot. <br />Natural regeneration of species in the plot from live handled topsoil <br />will provide a measure of protective cover as well. Tfre site will be <br />monitored for any erosional problems that may occur and mitigative <br />nieasur•es will be consistent with the rill and gully management plan at <br />Seneca. In the nonseeded areas, rills or gullies in excess of nine <br />inches will be filled and then stabilized with a protective mulch. This <br />procedure will be monitored for effectiveness. • <br />39 <br />