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Permit Revision No. 7 -Responses <br />March 7, 1997 <br />Page 2 <br />Soils Resource Information (2.04.9) <br />5. The SGFA Soil Resources map has been revised to identify the soil horizons to be salvaged <br />within each soil unit to be disturbed. The revised map should replace the map in the Soils <br />Investigation report in Exhibit 27A. <br />6. As stated in Rule 4.06.2(5), to the extent practicable, the surface soil layer shall be removed <br />at a time when the physical and chemical properties of topsoil can be protected and erosion <br />can be minimized. This statement has been added to the permit on page 2.05-56. <br />Vegetation Information (2.04.10) <br />A review of the vegetation narrative did not reveal a discussion of alternative reference <br />azeas. With the approval of the speciScs of the historic record approach proposed by MCC <br />within this revision, there will be no reference areas at the West Elk Mine. The area which <br />is currently being sampled to establish the historic record is referred to as the Historic <br />Record Study Area. The azea is located above and west of the mine portals in the azea <br />originally slated for the Upper Refuse Disposal Area. The Historic Record Study Area has <br />been added to Map 53, "Distribution of Surface Facilities at the West Elk Mine". <br />8. As stated in the response to question 7, there are no new reference areas. The Historic <br />Record Study Area was approved as a location for collection of historic record vegetation <br />information by CDMG in the summer of 1996. On or about August 13, 1996, the study <br />area was fenced with a three strand barbed wire fence to exclude domestic livestock grazing. <br />The fence will remain in place for the duration of vegetation data collection for historic <br />records purposes. Weeds will be managed in the same manner as described in MCC's weed <br />management program. After the standards are established, there will be no need to manage <br />the site for the long term. <br />9. It was MCC's understanding that CDMG, in the summer of 1996, agreed that three yeazs of <br />vegetation data would be sufficient to establish a historic record for the purposes of <br />establishing revegetation success standards for the West Elk Mine. It was agreed that <br />vegetation sampling would occur in three years which spanned the variability of <br />precipitation regimes at the mine; in other words, a wet yeaz, a dry year, and an average <br />year, based on review of precipitation data from a weather station in the vicinity of the mine <br />site. Therefore, it is possible that it may take more than three years of sampling to capture <br />the variability of precipitation regimes. Please see additional information in the next <br />response. <br />10. Savage and Savage collected information from the National Weather Service weather <br />station in Paonia, Colorado. The station is designated Paonia 1 SW. The station has been <br />in service since 1905 and has the longest weather record in the area. Based on the record <br />