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b. The section entitled "Transplanting" on page 4.4-21, was removed from the <br />revised pages. Unless there has been an approved change in the revegetation <br />plan regarding woody plant reestablishment, this section should remain in the <br />permit application package. Please revise the pages again to replace the section. <br />Section 4.4 has been revised to retain the section entitled, "Transplanting". <br />c. Section 4.4.4.3 was revised to eliminate the plan for woody plant monitoring. The <br />Division does not have enough evidence of successful shrub establishment at the <br />Edna Mine to justify deleting consideration of transplanting shrubs in an effort to <br />achieve the goal of I, 000 stems per acre in the Mojfa! area. Please replace the <br />discussion of transplanting or explain why it should be omitted. <br />Section 4.4.4.3 has been revised to include the transplanting of shrubs in the <br />Moffat azea. <br />13. Pages 4.4-20 and -21 include proposals to modify the interim and final vegetation <br />monitoring plans. Monitoring is proposed to be carried out by dividing the mine into <br />three areas. Those blocks are the West Ridge, Moffat area, and facilities areas. The <br />Division has several concerns about the adequacy of the proposed sampling design. In <br />order to expedite the renewal process, however, we would suggest that a stipulation be <br />added to the permit requiring a detailed sampling plan within 90 days of permit issuance. <br />The following points need to be addressed in the vegetation sampling plan: <br />a. West Ridge <br />Interim and final monitoring on topsoiled areas should also include belt <br />transects for woody stem counts, as presently approved in the permit. <br />Woody stem counts were never intended to be performed on West Ridge <br />since woody stem density is not a reclamation success criteria applicable <br />to West Ridge. Section 4.4 has been revised to clearly define the <br />reclamation success criteria applicable to each area of the Edna Mine and <br />what interim and final vegetation monitoring will be performed. <br />ii. The Division's bond release guidelines which P&Mrefers to, suggest that <br />reclamation blocks with different revegetation success standards (such as <br />areas with and without topsoil on West Ridge) be sampled as separate <br />reclamation parcels. <br />Section 4.4 has been revised to indicate that West Ridge will be divided <br />into a least two reclamation parcels. <br />iii. If vegetation sampling for final bond release were done during years 9 <br />and 10 ofgrowth of the 1996 revegetation, vegetation on other reclaimed <br />