2003-12-22_GENERAL DOCUMENTS - C1982057

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applicable to each is intermingled, which further confuses the issue. In some sections, critical terms aze not precisely defined, and in other cases, concepts and approaches are not clearly described and justified. There would seem to be no reason to apply one approach to success evaluation in the original permit azea, and a different approach in the South Extension portion of the permit area. The "best" approach should be selected, described, andjustified, and should be applied throughout the permit area. Please submit appropriately revised narrative to replace the confusing narrative on pages 39a through 40b. 39. Please amend narrative regarding cover success evaluation for the tie-across haul road corridor on page 41 to clarify whether "total cover" is based on "first hit" or "all hit" data. 40. Please amend the discussion of "Cover" under Samnlino Methods on page 36, to define the relevant terms "total cover" "herbaceous cover" "all-hit cover" "t" hit cover" "1" hit herbaceous cover" °all- , hit herbaceous cover", etc., with respect to the point intercept method employed, to ensure consistent interpretation and application. 41. The species diversity standard described on page 43 and 44 includes two separate approaches for the primary upland communities, one applicable to the original permit area and a separate approach applicable to the South Extension Area, with additional standazds specified for the tie-across road corridor and. The approach specified for the South Extension area would appear to be equally applicable to the mine area portion of the original permit area (Tie-across road corridor excluded). Please consider amending the Species Diversity section of the permit narrative on pages 43 and 44 to apply the South Extension approach (which combines relative cover assessment and species density assessment) to the entire permit area (excluding the tie-across road corridor). 42. As with cover and diversity, there appear [o be two different standards of success for woody plant density, one applicable to the original permit area and a different standard for the South Extension Area. For both the original permit azea and the South Extension Area, there is a standard of 2000 stems per acre within concentrated upland shrub and tree planting areas. For the original permit area, there is an over-all woody plant density standard of 450 stems per acre, while the over-all standard for the South Extension Area is 200 stems per acre. There would appear to be no particular reason for the original permit area to have a higher over-all standard than the South Extension Area. The Division would consider approval of a revision request to reduce the over-all standard for the original permit area to be consistent with the standard for the South Extension Area. 43. A revegetation monitoring program to include quantitative monitoring of specified reclamation pazcels based on year of seeding (quantitative monitoring during second or third growing season and periodically thereafter (every 2 to 4 years) is described on page 34 and 35. For the 2004 field season only, we would request that the monitoring plan be amended to focus specifically on success of woody plant establishment within designated woody plant establishment areas. Please submit an amendment to the revegetation monitoring narrative to specify that woody plant density monitoring will be conducted in 2004 within each designated concentrated shrub establishment area that was initially planted in 2001 or earlier. Specify a sampling intensity that will allow for meaningful comparison to the approved 2000 stem per acre standard. Each of the areas sampled should be accurately delineated on a sampling map to be submitted with the annual revegetation report in early 2005. Please state in the amended narrative that the monitoring report to be included in [he 2004 annual revegetation report will assess both shrub establishment success within individual concentrated planting areas evaluated during 2004, and shrub establishment "over-all" success based on previously conducted annual monitoring. Further, please state that the report will include recommendations for appropriate remedial or enhancement treatments to be applied within specified concentrated shrub establishment 19