2013-03-28_REVISION - C1981014 - Laserfiche WebLink

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Page 3 of 4 March 28, 2013 EFCI contends that the proposed Pinyon/juniper reference area is suitable. EFCI provided additional discussion regarding the applicability of the proposed Pinyon/juniper reference area, and the unsuitability of the existing Ponderosa /pinyon/juniper reference area portal disturbance area. The Division finds the additional information acceptable. Please find three items than need to be addressed by EFCI before the Division can proposed a decision on TR39: 6) The plant community delineations in the copy of revised Map 16 submitted to the Division with TR39 are too faint. Please submit a copy of Map 16 with the plant community limits clearly delineated so the definition is clear when the map is scanned electronically. 7) The material submitted with TR39 provides proposed text to revise permit pages 2.04.10- 4 and 2.04.10 -5, but the submitted page is incompatible with inclusion into the approved permit pages. Please submit a revised page 2.04.10 -4 and 2.04.10 -5 that can be inserted into the approved permit. 8) Please define the location EFCI wishes the vegetation monitoring data to be inserted into the permit. Since the approval of the proposed reference PJ reference area is based upon this data, the data needs to be a part of the permit and not a separate report. Inclusion into an exhibit may be an appropriate location. This may nessecitate an updated table of contents. Thourough review of the proposed Refernce area data finds: • The proposed reference area for the Pinyon Woodland community will result more stringent reclamation success standard for live vegetative cover. • The data provided in the application measured the cover on the proposed reference area at 23.07% versus the 11.39% cover measured in the baseline data Plot B. • The proposed reference area also indicates that the proposed reference area has a higher amount of shrubs and trees with 66.76% relative cover, versus 38.66% relative cover in the baseline data. The proposed PJ reference area measured the woody stem density at 6375 woody stems per acre. • The proposed reference area is larger. 1.75 acres versus 0.3 acres. • The approved PPJ reference area is showing evidence of die -off. The Newlin Creek area has experienced several years of droughty conditions. Juniper and Pinyon pine die -off has been observed throughout the area. Although some trees have shown die -off in the proposed reference area, it does not appear as pronounced. Please provide a clearer copy of Map 16, revised pages 2.04.10 -4 and 5, instruction as to permit placement of the supporting Pinyon/Juniper reference area vegetation report and an updated table of contents as applicable. The revised copy of Map 16 should also show that the proposed reference area boundary has been adjusted to eliminate the linear feature on the southern extent.