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• I understand the request this is proposed because of Kerr's concem regarding a <br />comparison between an herbaceous reclaimed community and a predominantly <br />woody reference areas. Canadian Strip Mine is referenced as an example of <br />where this approach was used. However, this approach was not used at Canadian. <br />Direct comparisons of total vegetative cover (minus noxious weeds) between the <br />sage reference areas and reclaimed lands was used at Canadian and other mines in <br />the State. There is no basis for the multiplier concept. Reference to the multiplier <br />needs to be deleted and replaced with a comparison of total cover. <br />Kerr is proposing to reduce the shrub density standard from 2000 stems/ acre to <br />500 stems/acre over 60% of the reclaimed area. Kerr says the 2000 stems may <br />not be desirable for the post mining land use. Please explain further. The Division <br />of Wildlife (DOW) and the BLM aze evaluating the reduced standazd in terms of <br />wildlife habitat. When I receive their comments, I wilt forward them to you. <br />If the reduction is acceptable to DOW and BLM, what 60% of the reclaimed area <br />will be used to evaluate shrub density? Why was 60%o of the reclaimed area <br />selected? Please explain how 60% of the reclaimed area for shrub establishment <br />was derived. <br />The standard for species diversity on page 780-84a is acceptable. <br />The decision deadline for TR-l9 is February 19, 1999. Please feel free to contact me if <br />you have any questions regarding the questions in this letter. <br />Sincerely, <br />(~-N_~_ <br />Sandra L. Brown <br />Environmental Protection Specialist <br />cc: George Patterson <br /> <br />