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result in enhanced revegetation success in cheatgrass infested azeas. However we have <br />concluded based on review of the referenced pernut sections that the soil handling <br />procedure needs to be more fully described, and the suitability of subsoil that would be used <br />as topdressing needs to be clearly documented. The plan should be amended to address the <br />following concerns: <br />a) It is not clear that the procedure described on page V-26 (stripping of top 6" of topsoil <br />from salvage areas and cheatgrass infested topsoil stockpiles and replacement at bottom <br />of lift) corresponds to the more generalized description of reverse sequence soil <br />handling as described on page V-33. The latter section indicates that the procedure <br />would entail placement of subsoil over topsoil stripped from cheatgrass infested salvage <br />azeas in "live handle" operations, and placement of material from subsoil stockpiles <br />over cheatgrass infested topsoil from stripping areas or topsoil stockpiles. Please amend <br />these sections as necessary for consistency. <br />b) Please identify the specific soil types or (or other appropriate azeal designations) within <br />future refuse sub-areas where cheatgrass is a significant stand component, such that <br />"reverse sequence" handling would be practiced, and address how reverse sequence <br />salvage and replacement areas would be delineated and managed in the field. <br />c) For refuse sub-areas or portions thereof where reverse sequence stripping would be <br />practiced, please define the thickness of the topsoil layer that would be stripped and <br />replaced in reverse sequence (e.g. beneath a layer of subsoil). <br />d) For soil types where reverse sequence stripping would be practiced, please define the <br />maximum thickness of subsoil material that would potentially be salvaged for <br />immediate or eventual use as topdressing, and reference the applicable soil sample data <br />and evaluation which demonstrates the suitability of that subsoil for use as topdressing. <br />Provide a plan for additional sampling of any soil types where subsoil is proposed for <br />use as topdressing, but subsoil horizon data by 12" sample increments is not available. <br />e) Provide documentation of suitability (or a plan for documenting the suitability) of <br />materials currently stored in subsoil stockpiles, that would potentially be replaced as <br />topdressing. <br />f) Please provide detailed design plans including plot location and layout for the field <br />studies described on permit page V-33. Identify the source areas for topsoil and subsoil <br />to be used in the test plots, as well as soil handling procedures, and plans for soil and <br />vegetation monitoring. <br />Deserado Mine Apri130, 2002 <br />