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David Berry -20- June 20, 1996 <br />proposes that the species diversity standard for the upland <br />seed mix reclaimed areas, which includes both the JW and MS <br />communities, be as follows. At least four perennial species <br />will have a relative cover exceeding 38. Of these species, at <br />least one will be a forb or shrub species. Applicable <br />perennial grasses will be cool-season species. Revised page <br />2.05-56 is enclosed. <br />75. At present, given the status of the regulations, BRL accepts <br />the DMG's proposal of a weighted average comparison method of <br />determining success. It is emphasized that both the DMG and <br />the operator agree that given the exceptionally high cover <br />values of the Mountain Shrub community in particular, success <br />based on a reference area comparison, direct or weighted, is <br />excessive. In agreement with the paragraphs above and below <br />adequacy issue 75 on pages 24 and 25 of the Division's <br />responses, the operator is anticipating revisiting the success <br />standards once the regulations are changed to accommodate the <br />technical standard alternative. Revised page 2.05-55 is <br />enclosed. <br />76. The cover standard for the Disturbed Meadow area is discussed <br />on page 2.05-56. This page will be revised to include a <br />production standard. Based on the baseline data, perennial, <br />non-noxious species contributed 1602 lbs/acre of dry weight <br />production to the overall value. 1602 lbs/acre is therefore <br />proposed as the technical standard for the Disturbed Meadow <br />area. Revised page 2-05-56 is enclosed. <br />77. No comment at this time regarding the acid generating <br />potential of the coal. <br />78. Air Emission Permits will be transmitted to the DMG as soon as <br />they are received. <br />79. The DMG's comments regarding the fact that there may be <br />limitations on speeds due to fugitive dust potential is noted. <br />80. At the DMG's request, page 2.05-47 was revised to incorporate <br />randomly placed rocks and/or rock piles into the reclamation <br />plan. Enclosed are revised pages 2.05-47 and 48. <br />81. Regarding comments from the USFWS concerning water depletion <br />and conservation measures for the Colorado River. The USFWS <br />will only consult with another Federal agency on this matter. <br />It is the DMG's responsibility to get OSM involved so OSM can <br />request a biological opinion from the USFWS. <br />82. On page 2.05-68, it is stated that the quality of the water <br />contained in the springs and seeps will not be diminished by <br />mining operations. The DMG requests that BRL comment on the <br />