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upland wildlife habitat post- mining land use. While no scientific sampling of this <br />area has been completed, it is clear from observation that the 1000 stem per acre <br />shrub standard is far from being met. However, the success and the diversity of the <br />shrubs that do exist on this area is encouraging and may indicate a minimum degree <br />of success that could be achieved if a shrub requirement in some form is maintained <br />in the future for this site. <br />Summary <br />NECC believes that the current revegetation plan regarding shrubs is technically <br />flawed, arguably unnecessary, and clearly financially unsustainable. The plan as it <br />currently exists not only inflates the required bond amount long before reclamation <br />occurs but results in a cost prohibitive expense to complete the plan, with almost no <br />chance to be successful over the revegetation liability period. <br />NECC is considering proposing a revision to permit #C- 1981 -012 that includes the <br />following changes; <br />• Requesting that Pond 4 and Pond 8 remain as permanent impoundments. <br />Pond 4 would remain for the reasons previously discussed regarding the <br />naturally occurring riparian habitat that currently exists. Pond 8 would be <br />retained below the RDA for continued sediment control following bond <br />release as well as to provide a permanent source of water for wildlife using the <br />reclaimed RDA area. A water source north of the Highway may reduce <br />wildlife from crossing the highway to the river. <br />• Removing a shrub standard over the entirety of the NECC reclaimed areas. <br />Shrubs are included in the current rangeland seed mix. If necessary, different <br />or additional shrubs could be added to the seed mix for a long -term shrub <br />component. As an alternative, if determined necessary, NECC would propose <br />to establish small' /4 acre shrub clumps in up to five' /4 acre areas, selected <br />based on proximity to wooded areas, water sources, other considerations as <br />determined by land owners and agency discussions. These areas would be <br />fenced over the revegetation liability period and techniques including limiting <br />grass and forb competition and species selection would be included. A <br />success requirement or standard would be determined in consultation with the <br />DRMS. <br />As not only a surface owner and coal lessor, but as the State wildlife management <br />agency, we would appreciate your thoughts with regard to this preliminary proposal. If I <br />can answer any questions you may have please call me. <br />Sincerely, <br />Kent Gorham <br />Principal /Technical Services, Gorham Energy Consultants <br />