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smooth brome, which dominated the site early in the liability period, appears to have died out. Alfalfa also appears to have largely disappeared, and perennial grasses other than Russian wildrye are minor components. The extent to which the irrigation practices may have contributed to the relatively poor stand observed is unknown, but at a minimum it seems likely that the irrigation might have enhanced the growth of smooth brome early in the liability period, at the expense of more drought adapted species. Narrative in the second paragraph of p. 22-10 of the NH-1 permit application package (PAP), indicates that the upland sagebrush reference area in the vicinity of mining areas 2 and 3 is the only reference area that exists for the Nucla Mine. This statement is apparently outdated; a reference area on airport property was approved in 2000 to replace the sagebrush reference area. Please amend the page 22-10 text to clarify that the sagebrush reference area has been replaced in by a reference area on the Nucla/Naturita airport property. 2. Narrative on p. 22-13 through 22-15 of the NH-1 PAP, and Exhibit 22-2 on p. 22-16 are also outdated, as the reference area location has been relocated from the area described (BLM property west of the airport) to inside the fenced airport property. Please amend the text and Exhibit as appropriate. 3. Table 22-5 on p. 22-17, and text on page 22-20, of the NH-1 PAP indicates that a species diversity standard of three perennial grasses, with each providing at least 3% relative cover, applies to the NH-1 dryland pasture areas. This conflicts with narrative on page 32 of the Division's March 18, 2003 Proposed Decision and Findings of Compliance (2003 findings document), which states that species diversity standards do not apply to dryland pasture reclamation. Please address the discrepancy. If the Division approved a waiver of the diversity standard, please reference the applicable revision action and amend the Table 22-5 accordingly. 4. We note that Table 22-5 indicates that the cover standard applicable to NH-1 dryland pasture reclaimed areas is "90% of the live perennial cover of dryland pasture reference area'. We would point out that applicable regulations in 4.15.8 do not specify that cover success demonstration necessarily be based solely on perennial vegetation. Narrative under Item 3, paragraph 2, p. 11, of the Division's April 1995 bond release guideline document, addresses the extent to which annual and biennial species maybe allowed to contribute toward demonstrations of success. The allowable relative cover and production contribution of annual and biennial species should not exceed f 0 percent, or the relative cover and production o/such species in the associated reference area or standard, whichever is higher. Annual or biennial cover or production in excess of this threshold should be deleted from fhe reclaimed area data prior to success comparison. An acceptable alternative is to delete all annuaUbiennial cover and production from both reference area and reclaimed area data prior to success comparison. WFC may wish to consider proposing an amendment to the specified criteria, to allow for inclusion of an annual biennial component for success demonstration. 5. The Sample Techniques and Design section of the NH-1 PAP, p. 22-22 through 22-25, is somewhat outdated, containing outdated references to data collection in 1999 and 2000 and the sagebrush reference area, and also reference to sample adequacy and hypothesis testing formulas in the 1995 guidelines document. Specific sampling timeframes mentioned may be overly restrictive; a June through September sampling window would allow sufficient flexibility to coordinate sampling with growing conditions in a given year. Sections of the guideline addressing statistical methods have been