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9. Typically, respread topsoil is chiseled or disced in order to avoid <br />overcompaction. Section 4.3.5 of the permit application does not address <br />this potential problem. How does P8M proposed to avoid topsoil <br />overcompaction in compliance with Rules 4.06.4(2)(b) and 4.06.4(1)? <br />10. Figure 2.4-1 identifies five reference or "control" areas. Three of <br />these are described on pages 2.4-4 through 2.4-8. Mention of the <br />Terrace Sagebrush and Chicken Sagebrush communities was not found in the <br />permit application. Please indicate where background information <br />describing these reference areas can be located in the permit application <br />or submit pages for insertion into the permit application. <br />11. Please expand the reference area narrative on page 2.4-10 to address the <br />following: <br />A. Why is the oak reference area located, as indicated in Figure 1.4-1, <br />inside a delineated snowberry sage area? <br />B. How close to the-edges of reference areas are mining operations <br />expected to come? <br />12. Page 4.4-1 of the permit application states: "Preliminary surveys and <br />evaluations of revegetated areas will be conducted during the second <br />growing season." On page 4.5-1, P&M commits to at least biennial <br />surveys. However, P&M needs to more specifically describe in the permit <br />how they intend to comply with Rule 4.15.1(4). This should include: <br />A. Vegetation parameters that will be sampled; <br />B. Sampling techniques to be used; <br />C. A schedule for monitoring data report submittal; and, <br />D. A format for the monitoring data reports. <br />13. Page 2.4-10 states that pre-mine woody plant density was sampled using <br />the angle-order method. One of the more obvious reasons for doing this <br />was that the density of stems found in pre-mined areas was very high. <br />However, because reclaimed areas are expected to have much lower <br />densities and the woody stem density standard to be achieved is <br />1,000 stems per acre, the Division requests that P&M adjust Section 4.4.5 <br />to commit to using the sampling procedure outlined on pages 8 and 9 of <br />the Division's Revegetation Guidelines for future inventories. The <br />requested sampling procedure is preferred to using the angle-order method <br />for areas with lower stem densities. Furthermore, Section 4.4.5 should <br />indicate that both diversity and density of woody stems will be evaluated. <br />-10- <br />