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' ~~, <br />• -7_ <br />7. The statistical evaluation~of reference area comparability will be on <br />the basis of total cover and production data. Because of the effect of a large <br />weedy component (cheat grass) on cover and production data, the reference data <br />will be qualitatively assessed with respect to the perennial component to <br />determine comparability with the affected area. <br />Reference areas, particularly in the Salt Creek flood plain, should be fenced <br />to conform with 4.15.7(3)(d) to bring it to at least fair condition. Observation <br />of the reference area in Salt Creek indicated poor condition because of over- <br />grazing. Fencing should also be considered for other referenced areas if they <br />are in less than fair condition. <br />8. The Division has not yet resolved whether or not the annual component <br />should be included in the post-mining sampling for bond release. This problem <br />is still under consideration. <br />9. No method is presented for demonstrating the achievement of adequate species <br />diversity as required in 4.15.8(5). Please submit such a discussion. <br />10. No indication of the seasonal variety of the proposed seed mixture is <br />offered by the applicant as required by 4.15.8(6). Please include a discussion <br />demonstrating that the proposed seed mix is of the same seasonal variety as the <br />natural vegetation. <br />11. The applicant has not addressed provisions in 2.05.4(2)(8) on management <br />of borings and drill holes. Also address items required in section 4.07 which <br />apply to your situation. <br />2.05.6(1) Air Pollution Control Plan <br />1. The Emission Permit covers only the use of the conveyor, crusher, and <br />surface work vehicles. The permit and the application submitted does not <br />address the control of fugitive dust from coal stockpiles, treating loaded haul <br />trucks, coal transfer, loading points, and conveyors. <br />2. Available total suspended particulate (TSP) data collected on site should <br />be provided if one or more quarters are available. <br />3. Specific monitoring locations should be documented on a figure. <br />4. A copy of the emissions permit from Colorado should be part of Appendix E. <br />2.05.6(2) Fish and Wildlife <br />1. No discussion is given regarding the nutritional value of the proposed <br />vegetation mixture as required by 4.18(4)(i)(i)(A). <br />2. The application mentions a proposed rail line corridor (p. 4-77). The <br />Colorado Department of ~dildlife has expressed concern over whether it is located <br />in riparian vegetation (Dow letter, March, 1979). Please specify the location. <br />2.05.6(6) Subsidence <br />Section 2.1.9 of the permanent program permit application includes the statement <br />that; "convergence data and observation of rib stability obtained to date during <br />exploration activities have shown no abnormal movement". The application should <br />