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Comment 2: So that brings us to what is being mitigated and what is not in this phase. <br />Mitigating permanent Impacts: <br />Page 14 and 15 mitigation totals are 0.09 acre upland and 0.07 acre riparian. <br />It gets confusing to assign these to offset specific permanent impacts (0.08 upland, 0.14 riparian), <br />in part since they don't provide adequate mitigation for those impacts, for riparian even at 1:1. <br />Also, we suggest mitigation for permanent impacts on the order of 1.5 -3:1 (depending on <br />restoration of non habitat vs. enhancement of existing, etc.). So this means you are substantially <br />shorter than just not mitigating 0.07 acre of permanent riparian impact (bottom of page 16, Table <br />11 doesn't work) <br />(Hey, for mitigation area one I get 2.6 shrubs for every 10 foot center (not 3 to 5). In contrast, I <br />calculated 3.8 shrubs every 10 foot center for the other 2 areas) <br />Mitigating (Restoring) Temporary Impacts: <br />Comparing impacts (0.28 riparian, 1.31 upland) in Table 10 (p. 18) to the bottom of page 16, it <br />appears that none of the 0.28 temporary riparian impact is being restored and 1.25 of the 1.31 <br />upland temporary is being restored. Similarly, we generally recommend mitigation for <br />temporary impacts at 1.5:1. On page 13 -14 it sounds like restoration areas only get a seed mix. <br />Do they also need planted trees or shrubs? In all cases sizes of trees and shrubs planted should <br />be specified (this may be somewhere in the package). <br />Trees: <br />IRIS <br />MITIGATION AND DESIGN, INC. <br />Environmental Consulting <br />IRIS MITIGATION AND DESIGN, INC. <br />3450 W. 32nd Avenue, 2nd Floor <br />Denver, Colorado 80211 <br />Phone: 720 - 272 -1985 <br />bleisure @irismitigation.com <br />We also recommend ratios for trees: 1 to 1 might be o.k. for non - natives and below some <br />minimum diameter, but trees impacted above 4" dbh it should go up. The Corps may have <br />standard ratio or Matt could suggest what he uses. <br />Response 2: We will change our mitigation ratio from 1:1 for the permanent upland and riparian <br />area mitigation to a 2:1 ratio (0.04 acre permanent upland area impact will require 0.08 acre <br />upland area mitigation and 0.1 acre permanent riparian area impact will require 0.2 acre riparian <br />area mitigation). We will also increase the temporary upland and riparian area mitigation ratio <br />from a 1:1 to a 1.5:1 ratio (1.3 acres of temporary upland area impact will require 1.95 acres of <br />upland area mitigation and 0.36 acre of temporary riparian area impact will require 0.54 acre <br />riparian area mitigation). These changes will increase the amount of mitigation that will be <br />required at the end of Phase 3 of the project (see Table 1). <br />Schwartzwalder Mine Phase 1 Page 3 October 2011 <br />Response to USFWS Comments <br />