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2009-07-30_REVISION - C1981008
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2009-07-30_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 3:49:15 PM
Creation date
7/31/2009 9:29:07 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
7/30/2009
Doc Name
DRMS Request for Permit Revision
From
DRMS
To
Western Fuels-Colorado
Type & Sequence
PR6
Email Name
MLT
Media Type
D
Archive
No
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See dew 'o?tme? ? ?, re?ardin err?ar?eous ?'ab ?? ?'ab?e of ar?tent Pale ?t??tberin, <br />See e? 'omr?e?? 20, regardi?r ques?tart ?v?ty ?roduc?ion standard for ? I r??ne area <br />is based arz a ?ec?rnica? standard rat?rer that refet?e?ce area comparrsa?r. <br />2. This comment also pertained to reference area status and location for NPI-l mane areas. <br />Pease refer to requested dap 2?-? snap ctari?ication in Item 1, ahnve. <br />?. ?114LR had pointed out discrepancies between current findings of corrapliance narrative <br />?.nd Permit Applieatlnn Pael?ae PAP} information regarding species diversity criteria. <br />applicability to NH-1 Dryland Pasture reclamation areas. Table ??- and associated <br />narrative was amended to clarify that the diversity standard for NH- l is applicable only to <br />Rangeland areas, not to ?rylnd Pasture teas, which is consistent with the r?axrative of <br />pale 32 ofthe findings hand also consistent with success standards for N?-? Dryland <br />Pasture}. item Resolved. <br />See env `?r?rnent ?1, reardin? the need for quality ?e.g, species or ??f ? font ?o?nposx??art <br />criteria app?icab?e to ?ry?artd pasture, ?rriated Pastore, a?td ?rriga?e? ?raplart <br />reclar?atiar?. <br />4. ?ILR had noted an alternate approach to reference area cover comparison that the <br />operator might want to consider. operator responded that the currently approved <br />cornparisan approach based solely on perennial cover would b retained. Ytem Resolved, <br />5. OIVILR noted that the sample Techniques and design section of the PAP applicable to the <br />N? 1 mine areas was substantially outdated, and requested that the section be amended to <br />ensure conformance of sapling and statistical det?onst?ation rraethods with Rule 4. I x.11. <br />This concern was addressed by revised aznplin Techn??u? and De?i?n section on <br />amended page 2G and 27 of Tab ??, and revised Rcye?etation ucccss criteria and <br />statistical Procedures narrative on pages 2? through ?? ofTal? ??. The revised ection? <br />are in general conformance with applicable sections of Rule 4,15.11, but certain <br />clarifications appear to be warranted: <br />a? Narrative states that herbaceous production will be treasured "at reclairncd areas <br />and the reference area', 'his does not correspond with Table ?-?, which indicates <br />that ?°?0 of a 5?4 pound per acre technical standard is the production success <br />criteria for dryland pasture, for the NH? 1 Area ?. Please amend the appropriate <br />sections of the narrative or the table to ensure that the PAP is interna??y <br />consistent. <br />Sep e? amr?er?t ?, reard?? ?es?i?rt ??by produe?ion s?ar?dard for -? ?i?c <br />areas is based o? a tec?t?rical standard ra??t?r ??tan reference area ca?tparisor?, <br />b? Narrative in ampl?ng Techniquc? and Desi and Re?egetation Success rite?.a <br />and Statistical Procedures of amended Tab ?? seems to be directed specifically to <br />success evaluation for N?- I I?ryland Pasture areas. Please amend tie narrative <br />
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