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- 12 - 3.~? The application proposes establishment of approximately 60 woody stems `~ per acre from mature transplant clumps and the planting of approximately 100 woody seedling stems per acre. Thus, in order to meet the woody stem density standard of 1000/acre, a major portion (around 900 stems/acre) of the woody plants would have to establish from natural or artificial seeding or vegetative propagules. Does monitoring data collected at the Eckman Park Mine indicate that such results would be expected? Woody plant density data collected previously by CYCC at the Eckman Park Mine should be submitted for t inclusion in the application, G4 \\ A revegetation monitoring plan should be included in the application. At a minimum, the plan should include provisions for collecting representative data on first year establishment (density and/or frequency would be appropriate) and 3rd or 4th growing season cover, species composition, production and woody density. The plan should also commit to submittal of such data to the Division at permit mid-term and permit renewal time. ~(1 V `~ The plan for monitoring vegetation in the aspen reestablishment test ~J plots should be included in the application, and that data should also be submitted to the Division at permit mid-term and renewal time. 3~ -6.~ ~ The applicant has proposed that vegetation monitoring be employed as a means of documenting adequate fertility of replaced topsoils, as ~;~ ,' opposed to regular testing of replaced soils. Oetaii regarding how the ~, ~. \ monitoring program would address this concern should be provided. For (~;~: example, if a 4th year revegetation stand does not meet reference area '' _ (' production levels, would a soil sampling and, if necessary, a ,~f.~ l fertilization program be undertaken at that time, even though the 10 year liability period would be reinitiated? ~;,~ ~~ Our concerns with the fertility status of replaced topsoils are `~' ;primarily in regard to long term stockpiled soils. Is information ,. .~~~ 'regarding the source (live handle versus stockpiled) of soil analyses ? .:ti ~ ~ presented in Exhibit 23 available? If so, are there any significant v ,,`,, differences between fertility levels of live handle and stockpiled topsoils? i,~ Fish and Wildlife - Rules 2.04.11, 2.05.6(2) and 4.18 1.~/ The applicant should commit to submitting all required wildlife monitoring data to the Division at appropriate intervals (e. g. elk, G~;.i passerine bird and raptor nest survey data should be submitted annually).