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<br />Johnston <br />July 19, 1994 <br />-4- <br />8. Based on the information in the articles I gave you and common <br />wildlife management practices, it is evident that larger shrub <br />clumps with a higher density of woody stems is more beneficial <br />to wildlife than those proposed by MCC. Larger, denser clumps <br />provide better hiding cover, thermal cover and a higher <br />comfort level in the core areas of the clumps. <br />Therefore, I disagree with MCC's stance that the minimum <br />effective size of the shrub clumps is not supported by <br />published material. <br />Frankly, the larger clumps are much more cost efficient, <br />easier to create and easier to maintain so I don't understand <br />MCC's reluctance to revise their plan accordingly. <br />9. The Division did not ask for facilities to be added to Map 58. <br />The Division simply asked for Map 58 to be updated to include <br />all disturbed areas to date. <br />The more area they disturb, the more area they have to <br />reclaim. Therefore, the requirements for location of shrub <br />clumps may change as disturbed area boundaries are pushed out <br />further and further with subsequent revisions. <br />When MCC disturbs new ground they must verify that existing <br />baseline data is accurate for that ground or collect <br />additional data for that ground. Then operation descriptions <br />must be defined for that area as well as proposed reclamation <br />procedures. <br />Each of these phases has map requirements ie: baseline <br />vegetation, soils and wildlife; disturbed area boundary, <br />sediment control; topsoil placement, vegetation establishment, <br />etc... MCC apparently thinks that they can update one <br />facilities map and neglect the others. It is not reasonable <br />to expect the Division to guess what resources exist or did <br />exist beyond the boundaries of outdated maps but within the <br />mines disturbed area boundary. In order for the Division to <br />evaluate proposed reclamation plans, we must be provided the <br />whole picture; not just the original out dated maps which <br />requires guesswork for the additional disturbed areas that are <br />not mapped. <br />I would not approve this revision without updates to all <br />appropriate maps, including baseline resources and reclamation <br />plans. <br />10. Response acceptable. <br />M:~099~f0~9~Op.666 <br />