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will be exceeded. Page 12-53 should note that there will be exceptions, and either list those instances on Page 12-53 or include a reference to Page 13-44. 6. Previously approved pages in Tab 13 were numbered 13-1, 13-2, etc. Revised pages do not have a Tab 13 prefix. In the interest of continuity, please revise the pages to include the prefix. 7. Table 13-1, Seed Mix No. 1 -Species number 3 is listed as Agropyron spicatum inerme. Agropyron spicatum is commonly known as bluebunch wheatgrass, while Agroovron inerme is known by the common name of beardless wheatgrass. Which species does PWCC plan to use in the seed mix? 8. As demonstrated by previous plantings of alfalfa (Medicag_ saliva), this species is very competitive. PWCC proposed to include a different alfalfa species, Medicag_o falcata in Seed Mix No. 1. We are unable to locate information regarding this species. Please provide the Division with more information concerning the species, specifically information to support that the species is less competitive. 9. Table 13-3, Seed Mix No. 3 - Medicag_o saliva. variety falcata is included in the mix. Is "falcata" a species or variety? 10. PWCC proposes concentrated shrub plantings in corridors and localized topographies. We agree that this can be a desirable method of shrub distribution. Exhibit 13-1 has been revised to show the general distribution of the concentrated shrub planting areas. Page 13-22 states that the areas shown on Exhibit 13-2 do not represent the acreage to be established. If these acreages are not representative of the acreages to be established, how will PWCC ensure that enough shrubs will be established to meet their woody plant density success requirement? Please submit to the Division the total acreage of concentrated shrub transplants so that we may verify that the success requirement can be met. 11. A statement on revised page 13-27 states that PWCC 'will use 200 Ibs/acre of 18-46-0 fertilizer." Is this application based on fertility analysis? If so, are the fertility needs homogeneous throughout the area to be reclaimed? Is there a reason the fertilizer recommendation is not site specific? Has PWCC had success applying nitrogen fertilizer at the time of seeding? Through inspection at other mines, the Division has observed that nitrogen application during the first year of seeding tends to encourage annual species and gives little benefit to perennial species establishment. Has PWCC successfully used this application? 12. Our Division and the Colorado Division of Wildlife (CDOW) disagree with the proposed reduction in the woody plant density standard. Comments from the Division of Wildlife are enclosed. CDOW contends that vast areas of primarily herbaceous vegetation are not beneficial to wildlife. The Division agrees that establishing shrub clumps and concentrated areas of shrubs is advantageous but believes PWCC should still meet the 1000 sterns per acre standard overall. ary en t 2 u y 13, 1 3