REV102981 - Laserfiche WebLink

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Mr. ~amer R Stark ' Cahrado Divirion ofMineroG eS'Geology AuBrrtt 7, 2002 Poge 5 reclaimed Mine Portal Area; and the Coal Loadout Reference Area (Grassland Type) to the reclaimed Loadout Area). Review, however, of the Mine Area Vegetation Map, (Map 16), and consideration of the previous response to Comment 17 indicate that much of the Mine Portal and assodated mine facilities azeas were included in the Grassland vegetation type and/or "Lands Disturbed by Previous Mining". It would be appropriate to evaluate these azeas against the Refuse Site Reference Area (Plot A -Grassland Type). Other site disturbance is very limited and would normally be evaluated against the Mine Portal Reference Area (Plot B -Ponderosa Pine-Pinyon Juniper Woodland Type). The CDMG has suggested, and EFCI concurs that a single weighted- average reference area comparison for the reclaimed Mine Area would simplify and facilitate revegetadon success evaluations. Accordingly, EFCI has developed aweighted-average revegetadon success standazd, reflecting pre-milting vegetation types and conditions. Based on the affected acreage of the two primary premine vegetation types within the mine disturbance azeas, the weighted average revegetadon success standazd will reflect 79.8 potent grassland (Plot A - Grassland Type) and 20.2 percent ponderosa/pinion/juniper (Plot B -Ponderosa Pine-Pinyon Juniper Woodland Type). Those portions of the reclaimed Loadout Area designated for a postmining land use of rangeland/wildlife habitat would be compazed to the Coal Loadout Reference Area (Grassland Type). Relevant permit text sections have been revised to accurately re Elect the basis for revegeta[on success evaluations for all disturbed azeas at both the mine and loadout and copies of the revised pages are included with this TR submittal. Comment 19 -EFCI har committed to exrenrive live rhrub and tree planting at the mine rite and the loadout. Pkare include a narrative in the revegetadon sections of the permit that includes the method and timetable far there tranrplantr as well ar a method for ensuring their long-term totters. Response: Section 2.05.4 (pages 2.05.¢23R and 24) currently provides a discussion of tree/shrub transplant plans, protective measures, and provisions for addressing seedling loss. Section 4.15 (page 4.15-3) references back to this discussion. It is anticipated that conventional transplant methods will be used, including selection of appropriate adapted transplant stock and selective placement of healthy labeling transplants with time-release fertilizer tablets to maximize the potential for transplant survival. Based on site conditions, including soil and prevailing atmospheric moisture conditions at the time, small diameter perforated pipe drains may be placed adjacent to the transplants, if appropriate, to collect and provide supplemental moisture during initial establishment. Protective netting may also be placed azound the transplants if there is significant potential for wildlife or rodent damage. EFCI will group transplants as "tree/shrub islands" both to improve the potential for seedling survival and to optimize the relationships between shrub and meadow azeas for grazing and wildlife use (i.e.: edge effect, cover zones, etc.). Transplant sites will be cazefully selected to optimize the potential for survival and subsequent natural re-seeding with consideration to aspect, micro-habitat, moisture, and location on slopes. Grass seeding rates will be reduced in transplant azeas to minimi>e competition. Both initial xevegetation success monitoring in Year-3 and informal site inspections will provide a good indication of transplant survival and any requirements for supplemental transplants or other measures. Information on transplant methods has been incorporated into the permit text and proposed transplant locations have been added to the reclamation map. Copies of the revised permit text and reclamation map aze included with this TR submittal. RULE 5.02.4 Comment 20 - Becaure the mine it curnently being reclaimed and the facilltier are being demolished and the entire area zr bezng backfilled and regraded, the Operator needy to relocate alt required recordr to a location that it accerrible to the public (ruch ar the county courthoure).