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success standards aze not becoming established, more intensive monitoring (including shrub patch mapping/sampling) and/or remedial measures may be warranted. I would recommend that we include the following comment in our response letter, and that this language be incorporated into the revegetation narrative of the renewal findings document. DBMS has concluded that the currently approved interim monitoring plan is adequate, and we will not require modification of the plan at this time. However, if review of monitoring data or field checks conducted over the 2007-2012 permit term within BRB-4 indicate a low potential for achievement of shrub standard success within a reasonable timeframe, monitoring plan modifications (to incorporate shrub patch mapping/sampling) and/or remedial shrub establishment measures may be required. DBMS will not be receptive to reduction in the woody plant density standard approved in TR-40, for BRB-4. Item Resolved. 2. SCC did amend the primazy upland seedmix to include mountain big sagebrush for BRB-5 azeas as requested, and the approved plan already specifies that "small seeded species" (which would include sagebrush) will be dribbled or broadcast on the soil surface and lightly covered. Further shrub establishment enhancement measures aze not proposed for BRB-5. In discussions with SCC representatives, they pointed out that there are several large shrub concentration areas in the immediate vicinity of the southern BRB-5 parcel, as indicated on Exhibit 13-13.3. They also indicated that a revision application would be submitted in the near future to request reclamation plan amendment for the northem BRB-5 pazcel (the shop facilities azea), to allow for retention of facilities for the postmine land use, in accordance with landowner request. My recommendation is that we include the following statement in our response letter: Given the seedmix modification proposed, and the other factors discussed, the proposed plan is acceptable. Should a revision application for facilities retention not be submitted within 2007, the Division may request that the reclamation plan for the BRB-5 northern parcel be amended to include appropriate woody plant establishment enhancement measures. Item Resolved. The "81-1"reclamation pazcel has been included within BRB-1, the "pre-law" bond release block. Appazently, the block was mined sometime prior to August 3, 1977, but was initially seeded in 1981. The question of whether the area had been initially disturbed prior to February 25, 1976 was not resolved, but the Division has determined that for the purposes of the bond release process at Seneca II-W, the determination would not make any practical difference. We have concluded that it is appropriate to include the vazious areas mined prior to August 3, 1977 within BRB-1, as indicated on Exhibit 13-13.1. This approach was