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Mr. Mike Boulay .Department of Minerals and Geology Page 4 This reference presupposes that the current rection of permit Tab 13, `Testing for Succesr~ul Reclamation'; winch extends frompage 13-34 to the beginning of the `4{eclamation Schedule"rection on page 1341, wi/l be retained in its cutnntfomr. However, this could lead to consfderable confusion in the future, since many of the success standards and testing approaches described in the Tab 13 text will be revised or replaced by standards and approaches of the new Appendix 13-13. In essence, the approved perruit wnn/d contain conflicting versions of applicable success standards and testing approaches. Deletion of the currently approved `Testing for Sucrerrful Reclamation"rection might be undesirable, however, due to the fors of documentation of the historical basis far same afthe nutters standard approaches that have been carried forward into the new Appendix 13-13. One possible solution would be as follows. Coate a new Appendix 13-14 `2lirtorical Approaches to Telling for Successful Reclamation, Permit C-80-0OS': Move the entire current `Testing... "rection into the new Appendix 13-14. Under the `Tertfng... "rection heading an page 13-34, inseK a new paragraph directing the Hader to Appendix 13-13 far the cu»xntly applicable success standards and testing approaches, and explain that Appendix 13-14 contains standards and approaches that are no longer in effect, but have been included in the appendix for historical purposes, and due zo the explanation of the rationale for ceRain approaches that have been mtained in the approved procedures of Appendix 13-13. Pleasegive consideration to the problem presented byreraining contlicdng versions ofsuccess standards and testing approaches in the approved permit, and propose appropriate amendments ro remedy the problem. Ifthe approach suggested by the Division is followed, the sentence referencing the permit docrunent under Cover and Production. could be amended to state, "The rationale for the factor ofZx...is explained its Appendix 13-14". Response: We are willing to proceed with the approach suggested, however the Division should note that the updated teat is based on revised text submitted in TR-37 (that hasn't been approved yet) and MR-53 text changes that have been approved (but based on preTR-37 changes). So if there are Division concems with the earlier TR-37 text revisions, they will cause a ripple effect through MR-53 and TR-40. 8. The SHRUB EVALUATION SECTIONof the appendix contains a den~iption of the approach to be employed to establish revised woody plant density rtandardr applicable to BRB-1, BRB-2, and BRB-3, ar well as woody plant density samplin8, evaluation, and tenting methods to be applied to there bond release blocks. The conceptual approaches are in line wit previous discussions between DMG and SCC staff. However, before thin technical revision application can be approved the redian needs So be `ylerhed out"by inclusion of the nearsary `high density"(minimum 1000 stem per acre) shrub patch mapping, and specified minimum aerialpercent of BRB-3 is be comprised of high-density patches. In additisn, woody plant density standards applicable to BRB4 and BRB-S blocks will also need to be addressed Please address these concems and provide new or amended tent and mapping as appropriate. Response: Relevant sections of the appendix have been revised or updated to address the Division's concems. Attached is Exhibit 13-13.3, Shmb Concentration Areas, which shows the locations of the mapped shrub concentration azeas.