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<br />than aspen, and include at least one experimental trial site employing the concept with tall mountain <br />shrub species, as referenced in Item 7, above. <br />Alternative Asnen Establishment Methods <br />Dr. Shepperd fett that, unless supplemental irrigation and browse protection were provided, various <br />techniques of live soil handling, sucker stimulation and live transplanting would likely have low <br />potential for success. He indicated that for live topsoiling to have the most potential for success, a <br />disking or ripping treatment following mature tree removal would be recommended, to break the aspen <br />lateral roots into shorter segments prior to soil salvage. The tree removal, disking, and salvage should <br />be conducted in the fall of a single season. Anydozer pushing or other treatments to stimulate <br />suckering should also be conducted in the fall, with live transplanting of suckers to be conducted the <br />following fall. <br />Please address the feasibility of live topsoiling and live clump transplanting aspen establishment <br />methods within the South Mine area, and include provision for at least limited use of these approaches <br />if operationally practicable, in accordance with Dr. Shepperd's recommendations. <br />11. Text on page 39 of Tab 22 was properly updated as requested. <br />12. Operator adequately responded to the question posed in this item. <br />Additional Comments tMinesoil Reconstruction. Snoil Grading, and Noxious Weed Controll <br />a) Various sections of Tab 21 need to be amended [o reflect the amended operational plans associated <br />with PR-3. Examples include the following: <br />• Drawing 21-1 "Topsoil Replacement" depicts replacement areas by year, but does not address the new <br />aeeas to be affected pursuant to PR-3. The map needs to be appropriately amended. <br />Page 21-8 (Revised 06/24/91) references topsoil salvage depths presented in Table 21-I, and summary <br />discussions in subsequent text sections. The final sentence of the T"paragraph of the Topsoil Salvage <br />Depths section states'No discussion is presented for Map Units 28A, 34E, 34F, 46B, V46D, SOE, <br />66E, 66F, 70D, 99 and RO which do not occur within the projected topsoil salvage area." In fact Map <br />Units 70D (Skyway Silt Loam, 15-30% slope), 34D (Coatis Sil[ Loam, 15-30) and 34E (Coatis Silt <br />Loam, 30-SO) are major soil map units in the South Mine Area, closely associated with the aspen <br />forest habitat. V46D (Splitro Variant (Stony) Loam) also actors within the proposed affected azea. <br />Text on page 21-8 through 21-21 needs to be updated as appropriate to address all affected soil types <br />in the mine plan area. Table 21-1 likewise needs to be appropriately updated. <br />• Discussion under Topsoil Salvage Techniuues, page 21-21 through 21-25 should be amended as <br />necessary to reflect salvage within the additional map units referenced above. <br />Paragraph 3 on page 21-28 references the desirability of direct haultopsoiling, and indicates that <br />"approximately five percent of the topsoil will be handled by the duet[ haul method during the fvst <br />permit term (Table 21-4). Narrative should be updated to address direct haultopsoiling in the South <br />Mine Area, with reference to amended Tables 21-4A and 21-4B. Narrative explanation should be <br />provided regarding why direct haultopsoiling is not projected for the Wadge Mining Area, and why <br />no projection is made regarding duect haul topsoiling for 2004 through 2012, in the Sage Creek/Wolf <br />Creek Mining Area. <br />• Paragraph 3 on page 21-31 references a mean topsoil replacement depth of approximately 1.3 feet, <br />which contrasts to mean replacement depths of 1.6 feet and 1.66 feet on Tables 21-4A and 21-46, for <br />the Wadge and Sage Creek/Wolf Creek aeeas, respectively. Text will need to be amended to address <br />replacement depths within the South Mine Area. <br />