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enhancement concepts and goals described may not be compatible with use of the <br />introduced grasses. <br />If it is ultimately determined that the goal described in Item "a" is appropriate, it is likely <br />that seed mix(es) will need to be revised, and that seeding practices in subsequent sections <br />of the revegetation plan will need to be amended to incorporate and further develop the <br />various diversity and shrub enhancement practices discussed in the "General Revegetation <br />Practices" section. Conversely, if it is determined that rapid establishment of a competitive, <br />persistent, perennial grass cover is the appropriate objective, then several of the Items in <br />"General Revegetation Practices" may need to be revised. <br />As with Item 1, please take these points under consideration and provide an initial, <br />conceptual response within your mid-term review response submittal. <br />4. Narrative on page V-51 related to herbicidal cheatgrass control and remedial seeding trials <br />conducted on portions of Refuse Area #1 in 2000 is written prospectively. Please update <br />the narrative to describe the results achieved and the current vegetative status of the <br />remedial treatment areas. Please include description of treatment, results, and current <br />status of vegetation cover on Topsoil Stockpile 2/3, near RP-1, which was also treated <br />in 2000. Also, please address the implications of these and other cheatgrass treatment <br />trials, and how the results have been incorporated into on-going cheatgrass control <br />efforts applied to reclaimed areas, topsoil stockpiles, and other stages of disturbance <br />and reclamation. <br />5. The introductory pazagraph of permit section V.J.1, on page V-53, should include reference <br />to Rule 4.15.11, which was incorporated into the DRMS regulations in 2005, in addition to <br />the other rules cited. Also, because Rule 4.15.11 addresses acceptable revegetation <br />sampling methods and statistical demonstrations for revegetation success, the reference to <br />the DMG "Guidelines Regarding Selected Coal Mine Bond Release Issues", in the <br />introductory paragraph of permit Section V.J.3, page V-63, should be replaced with <br />reference to Rule 4.15.11. Please amend the sections as appropriate. <br />6. Paragraphs V.J.3(e) and (g) are out of date, and (h) is no longer required, due to the <br />inclusion of specific sample adequacy formulas and hypothesis tests within Rule 4.15.11. <br />Please amend {e) and {g) on page V-64 to replace reference to the guideline with <br />reference to Rule 4.15.11, and delete the outdated paragraph (h). <br />[t is not clear how the "adjacent undisturbed azea" comparison approach and the paired <br />transect sampling technique described in Section V.J.3(d), on page V-63 would conform <br />with the acceptable success comparison approaches of Rule 4.15.7(d) or the acceptable <br />statistical sample adequacy and statistical success demonstration approaches of new Rule <br />4.15.11. It does not appeaz that multiple undefined adjacent areas would constitute a <br />reference area or azeas as defined and described in the regulations. It is not clear how the <br />sample -ocations for paired samples would be selected, or how many paired sample sites <br />would be necessary for each site or block of sites. It further does not appear that the <br />statistical methods for sample adequacy demonstration and hypotheses testing appropriate <br />