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3 VIe for non-irrigated crops. The definition of the VIe class was provided above. Ne soils aze defined by the NRCS as, "soils [having] very severe limitations that reduce the choice of plants, or that require very careful management, or both" due primarily to erosion potential. The range of capability classifications for the soils at the mine should be addressed. 3.3.2 Revegetation Techniques- page 17. "Eligible areas are fully sampled in years nine and ten prior to Foal bond release." To be correct this statement should be; "Prior to final bond release, eligible areas are sampled in the last two consecutive growing seasons prior to bond release, but not earlier than years nine and ten of the extended liability period." Section B, XV. Rule 4.15 Revegetation- page 28. With its statements; "two introduced species in the reclamation seed mia." and "sideoats grams and yellow Indiangrass were introduced.", the Division appears to be contending that sideoats grams and yellow Indiangrass are introduced species. sideoats grams and yellow Indiangrass are not introduced species, they are both native to the western United States and the eastern plains of Colorado (Walser C.H. 1982. "Ecology and Culture of Selected Species Useful in Revegetating Disturbed Lands in the West", U.S. Dept. of Interior, Fish and Wildlife Service, FWS/OBS-82/56). As these species are native, no approval for their use in the reclamation seed mix is necessary. This paragraph should be removed. CDMG also alludes to more than one reference area in paragraphs D, E, and F of this section. There is only one reference area which is used at the Keenesburg Mine, the Osgood Sand Reference Area, which is specifically discussed relative to revegetation success criteria on pages 114d and 1 14e of the Permit document. In paragraph D, the Division indicates that revegetation success criteria for the Keenesburg Mine are found in Rules 4.15.8, 4.15.9, or 4.15.10. The performance standards for revegetation success applicable to the Keenesburg Mine aze found only in Rule 4.15.8, since Rule 4.15.9 addresses standards for cropland (of which the Keenesburg Mine has none) and Rule 4.15.10 speaks to standards for previously mined lands (of which the Keenesburg Mine has none). Page 29, Section B, X VII. Rule 4.17 Air Resource Protection. "The permit includes CDPHE Permit 88WE031..." By copy of correspondence dated November 26, 1996, the Division was appraised of CEC's request to the Colorado Department of Public Health and Environment (CDPHE) for cancellation of Air Permit 88WE031. Then, by copy of letter received from CDPHE (Mr. Jce Molloy) dated December 16, 1996, the Division was notified of CDPHE's cancellation of this Permit, and redesignation of acitvities [o "APEN Required" status. and, "The permit currently retains C-84WE294P, October 11, 1984 (added a portable crusher) and 12,438 (FD) (actually 12WE438F), issued May 13,1982 which applied to surface coal mining and the coal processing plant with all associated equipment." Copies of correspondence between CEC and CDPHE dated July 9, 1996 and April 24, 1997 are attached for your reference (though it is believed the Division was supplied copies as events unfolded). The first letter was a request to CDPHE to consider termination of the two permits since the activities covered by them are no longer occurring. The follow-up letter from CDPHE was an acknowledgment of CEC's request and cancellation of the two permits. With this information for the CDMG files CEC believes that it is appropriate to remove both permits from any "active" reference within the context of the Permit.