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1 <br />L~ <br /> Please note that the boundary is somewhat approximate as the limits of <br />' M1 disturbance in this area are extremely vague due to the minor amount oP <br /> actual surface disturbance. All reasonable efforts were taken to include <br />1 all the disturbances, but the scale of the disturbances are very small in <br />comparison to the scale of the available mapping. The limits of <br /> disturbance are intended to be coincident with the revised Permit <br /> Boundary. <br /> <br /> ITEM NO. 3 RESPONSE: - To some extent the application oP the <br /> "surrounding areas" standard to this disturbance is unreasonable. Although <br /> the law and regulations clearly apply this standard, the area where the -- <br />' rocks rolled down the hill was not as heavily forested as the adjacent <br /> slopes. Therefore, if we reforest the land so It is equal to the <br /> surrounding slopes we will be establishing more trees than were originally <br />' there. The Operator therefore suggests two approaches to solving this <br /> discrepancy. <br />On the one hand, the tree density nett to the disturbance coulc! be <br />sampled for density. This could be used as the standard for planting. <br />However, this would cause a greater density to be reestablished than was <br />' originally there. An alternative would be to count the trees that were <br />actually destroyed (they are all still there) and reforest to that amount. <br />Although we are not against establishing more trees than. vaere... <br />' originally there, we do wish you to be fully aware that using the stand;;rds <br />in the law IN THIS CASE will be requiring a replacement in excess oP <br />what was originally there. In the event the MLRD decides that we sh~ruld <br />' use the "surrounding areas" standard In this case we will sample the trees <br />and commit to establishing a similar density, otherwise we will count the <br />destroyed trees and replace them to that level. As the data still needs to <br />' be collected, irrespective of which standard is applied, we agree to prop/ide <br />the appropriate data and use it as the basis for forest planting density <br />calculations. <br />' We think you may wish to consider another factor when making Dour <br />decision about which standard should be applied. The slope which was <br />disturbed is strongly dominated by Gambel Oak whereas the adjacent, snore <br />' dense forests have few shrubs. Therefore, in making your decisior, we <br />recommend you consider the competition that will occur in'establlshi.ng a <br />forest as dense as the surrounding slopes. We think, the presence of a <br />dense, highly competitive shrub will make establishing trees to the density <br />' seen on adjacent slopes Par more difficult. <br />ITEM NO. 4 RESPONSE: Please refer to the Ttem 3 response Por a <br />discussion of the disparity between actual disturbance and the standani Por <br />replacement. We agree to the five year term for establishment success, <br />although we feel that the difference between the success accomplished in a <br />three year term and a five year term probably would not be signifi~:ant <br />statistically. <br />1 <br />z <br /> <br />