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• Kerr is planning to conduct vegetation monitoring in the summer of 1999. <br />Presumably, the Pit l Area and 720 Pit will be included in this effort. Additional <br />monitoring for these two areas also needs to be undertaken at least one more time, <br />preferably, in 2001 to determine [he revegetation trends five-six years after <br />seeding. The application needs to be revised to address future revegetation <br />monitoring in the Pit L Area and 720 Pit in 2001. <br />Revised Page-l61 says during the period of liability, vegetation studies will be <br />conducted at 2, 4, 7, 9 and 10 years following the completion of permanent <br />seeding. This statement is inconsistent with what Kerr has said on pages 780-132 <br />and 816-155 as discussed in the preceding paragraph. Please revise the <br />application to be consistent. <br />13. Vegetation sampling is scheduled for 1999 and based on the results of this effort, <br />Kerr is planning to submit and implement a grazing plan for 1999 and subsequent <br />years. Have the coordination difficulties with the adjacent landowner been <br />resolved? <br />14. Kerr has revised the permit to indicate that pre-law aeeas will only be subject to a <br />cover standard. The cover will need to be sufficient to control erosion and will <br />apply to those areas seeded prior to August 3, 1977 as shown on Map 18. This <br />needs to clarified in the permit, page 780-84a and in Section 816.116. <br />15. Kea has four established reference areas to represent the communities disturbed <br />by the mining operations: Big Sagebrush, Sagebrush-gravel, Treated Sagebrush <br />and Alkali Sagebrush. A weighted average for each reference area will be based <br />upon the relative acreage of each plant community disturbed over the life of the <br />mine. Since all disturbance has occurred the relative acreage can be determined <br />now. Please submit a table showing how many acres of each vegetation type was <br />disturbed. Kea may want to re-evaluate whether all four reference areas will be <br />used for final revegetation success. <br />In the permit application Kea also proposes using the baseline data for any salt <br />flat vegetation that is disturbed. Based upon the size of disturbance to this <br />community, this standard may or may not be applicable. The disturbed acreage <br />information requested above will be helpful in answering this question. <br />For cover and production, Kea is proposing to compare the data from the <br />reclaimed areas to data collected from the four reference areas combined with <br />data from the Salt Flat vegetation type. Kea is proposing to use a one tail t-test <br />for comparison between the two at the ninety percent statistical confidence level. <br />This is acceptable however, Kerr references the MLRB 1988 Guidelines. This <br />has been updated for bond release in 1995 and should be consulted. <br />Kea has proposed eliminating the shrub cover from any reference area dominated <br />by woody plants and using a multiplier of 2.0 for the herbaceous component. As <br />