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29. NP states that Year 9 and 10 monitoring will be conducted in accordance with the sampling methods and statistical demonstrations set forth in Rule 4.15.11. Rule 4.15.11 offers several options. Please describe which sampling methods and statistical demonstrations will be used. 30. In the montoring pazagraph on page 2.05.4-10, NP states that monitoring will be conducted to evaluate revegetation trends and to determine necessary augmentation plans such as interseeding. Please note that the approved husbandry practices aze delineated in Rule 4.15.7(5)(a)-(g). Augmented seeding is not allowed. Interseeding is allowed to enhance species diversity if necessary based on the monitoring data. Interseeding is not an allowable substitute for complete reseeding when vegetative cover is deficient. Please remove or clarify the statement on augmentation and interseeding. 31. NP has presented a proposed seed mix on page 2.05.4-8 in Table 2.05.4-1. Intermediate wheatgrass, an introduced grass species, is the dominant seed. The Division recommends that the Intermediate wheatgrass be replaced by a combination of native cool season species such as: Junegrass, needle and thread grass, Sandberg bluegrass and thickspike wheatgrass or slender wheatgrass. The NRCS also recommended (Exhibit F) that the wane season species blue grams be included in the mix since blue grams is the primary native species in the azea. I would also suggest a couple other warn season grasses such as: buffalograss, galleta grass and ring muhly. Please revise the seed mix at a minimum to include bluegrama and to replace intermediate wheatgrass with one or more of the native cool season grasses. NP is proposing to apply mulch at a rate of 40001bs per acre. This is high and NP may want to reevaluate this mulching rate and reduce it by approximately one-half to around 2,000 lbs per acre. Additionally, certified weed free straw or hay mulch is recommended for the reclamation to minimize the possibility of importing weed and other undesirable plant species. 32. NP is proposing to generate approximately 10,000 cubic yazds of underground development waste (coal mine waste) during construction of the portal face-up azea. This material is proposed to be incorporated as part of the mine bench and then regraded into the post- mining topography upon completion of mining. Please explain how the placement of this material in the portal bench and handling during reclamation will comply with Rule 4.10.1(1) for coal mine waste banks. 33. Please ensure that baseline surface and ground water data collected since the application was submitted is incorporated into Exhibit L. Rule 2.05 Operations and Reclamation Plan 34. Please submit a hydrologic monitoring plan for the operational and post-operational period for the proposed mine. Monitoring locations, frequencies, and sampling parameters should be cleazly presented in tables and/or permit text For both surface and ground water.