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It may be necessary for the operator and relevant agencies to more explicitly choose what the focus of revegetation efforts at Deserado should be. One option would be to place the emphasis on the quick and reliable establishment of a (comparatively) "cheatgrass resistant" perennial cover using the aggressive introduced grasses as the primary component. A second option would be to focus on the establishment of diverse, predominately native communities, with significant representation of big sagebrush and associated species. This option would likely entail more extensive use of herbicides and other specialized management approaches to suppress cheatgrass and enhance the establishment of the desired native shrubs and forbs. Approaches might differ depending on the nature and extent of disturbance (for example, "large permanent sites" versus "small and linear sites"). Also, depending upon the selected focus, revision of the success standards for woody plant density and species diversity may be warranted, and remedial treatment of previously reclaimed areas chazacterized by low diversity and/or low woody plant density may be warranted. Please take these concerns under consideration and provide an initial, conceptual response within your mid-term review response submittal. As a component of this mid- term review, we will also specifically request input on this matter from the Bureau of Land Management (the permit area surface land management agency) and the Colorado Division of Wildlife (responsible for consultation and approval of minimum woody plant stocking levels, planting arrangements, and methods for mitigation of potential adverse impacts on wildlife, pursuant to Rule 4.15.8(7)). A joint agency site visit to view current operations, previously vegetated areas, and planned future disturbance areas may be useful to resolve this issue, and we would like work with you to schedule such visit later this year. We anticipate that a request for more specific permit modifications to the seedmixes, success standards, and related provisions of the revegetation plan may be forthcoming following the site visit and consideration of input from all parties. 2. Please update the narrative in Section V.H of the permit application, at the top of page V-29, to describe the results of the initial phase cheatgrass/soil factor studies, with applicable data provided in tables or appendices. Implications of the initial phase studies on the field trial phase of the study should be described, and the field trial plan should be amended as appropriate. If initial phase studies have not been performed, please provide a schedule in the amended text for completion and reporting of initial phase results prior to the next cycle of refuse pit reclamation. Discussion under Item "a", of the "General Revegetation Practices" section at the top of page V-31 is relevant to the issues raised in Item 1 of this letter. The concept described is that "as natural successional stages advance, the ecosystem will mature by the continued growth of the shrub component and dispersion and establishment from adjacent endemic ecotypes and species". This successional sequence may be disrupted or severely delayed by use of the aggressive, persistent, introduced grasses. Various other Items in the "General Revegetation Practices" section related to diversity enhancement and establishment of big sagebrush and other native species with very particulaz establishment requirements aze relevant if the emphasis of the revegetation plan is to establish relatively diverse communities that will develop as described in Item "a". However, the diversity