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Page 2 of 4 <br />March 28, 2013 <br />Old road or waterline disturbance on south end of proposed PJ reference area <br />February 27, 2013 <br />2) EFCI has provided detailed tables with species cover information per transect as well as a <br />transect location figure. The Division finds this detail acceptable. <br />Please note that the Division has stated that raw data may not be required to be submitted <br />at the time of a bond release or technical revision application. However, the Division has <br />repeatedly stated that if we should request the raw vegetation sampling data after initial <br />review, the data should be available. This is not a policy change. <br />3) The Division had inquired into a reference in the Permit Exhibit 11 reference to "Permit <br />Area Figure 1" since the Division was unable to find the referenced figure in the <br />Division's records. EFCI stated that they did not have the referenced "Permit Area <br />Figure 1" in their records either. The Division believes the baseline vegetation types <br />referenced in "Permit Area Figure 1" have been incorporated into Map 16. EFCI does <br />not have a figure titled "Permit Area Figure 1 ". No additional response is necessary for <br />this item. <br />4) The Division's question asking if IME had sampled the Portal Reference Area during any <br />of the years that IME had sampled the reclaimed areas is not a departure for Division <br />policy. IME stated that they had been monitoring the reclamation success of the <br />reclaimed areas since 1987. Interim monitoring does not require statistical adequacy or <br />comparison to the reference area and is not required. The Division simply inquired if the <br />Ponderosa/Pinyon/Juniper reference area had been sampled, and if it had to supply the <br />results. A simple "no, the Ponderosa /pinyon/juniper reference area was not sampled <br />during the interim sampling events." is acceptable. <br />5) EFCI declines the Division's suggestion to use both the proposed Pinyon /Juniper <br />reference area and the previously approved Ponderosa /pinyon/juniper reference area. <br />