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r <br /> <br />6. The 9uestions raised concerning the surrounding lands are <br />of minimal concern to us because the size of the continuous <br />disturbed area is more of an issue. This is where the edge issue <br />comes from. If more islands of undisturbed vegetation were within <br />the permit area we would could live with fewer shrubs. <br />7. we are not prepared to discuss out-of-kind mitigation <br />regarding this TR. <br />8. we do not agree with the methodology that CYVCC used to <br />arrive at their edge figures. The small averages of improved land <br />that they subtracted from their analysis did provide edge and <br />should be added into the total edge. The edge that they are <br />claiming for the clumps is not justified. The clumps have not yet <br />evolved to the extent necessary to provide much edge. we have <br />digitized the premine vegetation map and calculated a reduced <br />edge of 60% from premine. If they are held to the standards that <br />they originally agreed to this site has the potential to be <br />returned to good wildlife habitat. Irrespective of al] of our <br />past disagreements about the impacts of surface mining on key <br />species this is one commitment that we have always counted on <br />being met to help minimize long term impacts on all wildlife <br />species. <br />The additional information provided by CYVCC has not changed <br />our position on PR-03. We still are opposed to the approval of <br />this permit revision. Please contact me if you have questions or <br />if you need additional information. <br />'ncerely, <br />im Morris <br />wildlife Biologist <br />