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38 186. LCC proposes to use an Extended Reference azea concept. Exhibit 10, pg. 1, states, "Extended reference areas were located throughout the permit area (outside any proposed disturbance area) and not in any one location." While the Division is not adverse to the extended reference azea concept the Division is concerned with how LCC will maintain the reference areas in accordance with Rule 4.15.7(3)(d)? "Reference areas shall be managed in a manner which is in accordance with the approved postmining land use far the area to 6e mined. " Please refer to page 10 of the Division's 1988 "Guidelines for Compliance with Land Use and Vegetation Requirements of the Colorado Land Reclamation Board for Coal Mining", which states, "Extended reference areas must be located outside of areas which would potentially be disturbed during the life of mine." The Division is concerned that portions of the extended reference areas could be disturbed in future revisions. An example of this potential exists currently with the proposed Grassland reference area. Only Lorencito Canyon grassland was sampled to establish representation of the mine area grassland community. Yet, maps indicate that the P 1/P2 haul road will be constructed through the grassland, the existing road will be upgraded to an access road, and numerous topsoil piles will be located throughout the grassland reference area. This constitutes a considerable potential for disturbance. LCC has not demonstrated that other grassland communities aze representative of the pre-mine surface mine grassland community. LCC needs to define in detail how reference areas will be protected from disturbance. 187. Table V-1 in Exhibit ]0, pg. 5, it appears that this table was not completed. The Permit Area Acreage column per community type has been left blank. The Proposed Disturbance Acreage for Grassland and Oak/Pinyon communities have been left blank. (4.15.7(3)(b)) 188. The Division has noted that values found in Exhibit ]0, Table 2, "Grassland Statistical Area Comparison Student t-Test", incorrectly reflect values found in the Oak/Pinyon reference azea, Table V-7. The Division is unable to adequately review this portion of the permit application with inaccurate data. Please revise these tables to accurately reflect the field data. (4.15.7(3)(b)) 189. An error is noted in Exhibit 10, Table V-8. There aze two column titled, "Mean Absolute Cover". The Division expects that the last column should be titled Mean Relative Cover. Please make the appropriate correction. 190. Rule 4.15.7(3)(b) states: The permittee .shall demonstrate statistically, !o the satisfaction oj[he Division, that each proposed reference area is comparable to its equivalent area to be disturbed in [erms of vegetative cover and herbaceous productivity and other