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Figures 4 and 5, on pages II.F-54 and [I.F-55 of permit application Volume 2, would <br />seem to imply that the sagebrush-grass reference area (0110) would be the standard of <br />comparison for upland sites at the rail loadout, "D" portal, haul road and refuse disposal <br />site, while the sagebrush-greasewood reference area (0140) would be the standard of <br />compazison for lowlands in the "D" portal area. The Colorado wildrye reference area <br />(0150) would apparently also be utilized as a standard of comparison for certain portions <br />of the "D" Portal upland reclaimed areas. <br />The specific method of reference area comparison, pursuant to Rule 4.15.7(4), should be <br />specified in the revegetation plan. [f the direct comparison approach is to be employed, <br />mapping or detailed description should be provided to delineate reclaimed surface aeeas <br />to be compared to each of the three reference areas. If a weighted average approach is to <br />be employed, explanation should be provided regarding the application of this approach. <br />A combination of the two approaches might also be appropriate (e.g. weighted average <br />upland comparison using Ol 10 and 0150 reference areas, and direct comparison of <br />reclaimed lowlands to 0140 reference area). <br />c) Statistical tests of success to be employed for vegetation cover, herbaceous <br />production, and woody plant density should be specified. The operator is referred to Part <br />4 of the Division's "Guideline Regarding Selected Coal Mine Bond Release Issues". <br />d) In Item 136 of the Mazch 5, 1997 review letter, the Division questioned the need <br />to sample herbaceous cover separately from woody plant cover as implied in the <br />revegetation plan narrative. No explanation for this approach was provided, but on <br />amended page 65, paragraphs (a) and (b) still imply that herbaceous cover and woody <br />plant cover would be measured on sepazate transects. Unless appropriate rationale is <br />provided for the alternative approach, the plan should describe sampling of vegetation <br />cover (herbaceous and woody combined) using the random transect point intercept <br />technique as described in paragraph (a), on amended page 65. <br />e) The large number of de-gas well sites, exploration drill sites, and associated light <br />use roads within the mine permit boundary, which have been permitted as revisions [o the <br />mine permit (rather than through exploration notices of intent), are subject to revegetation <br />success requirements and the bond liability period for coal mining. However it does not <br />appear that success criteria, standards, or sampling procedures applicable to such sites <br />have been defined. This deficiency will need to be addressed in amendments to the <br />revegetation plan. <br />14. a) i. The operator updated Map 77 to show three new culvert locations. The map <br />depicts a separation of Refuse Areas 2-3, and 4. Since these areas were combined into a <br />single Refuse Area 2-3-4 pursuant to TR-42, the map no longer accurately reflects the <br />approved drainage configuration or postmine contours. In order to accurately reflect the <br />approved plan, and avoid future confusion, Map 77 should be amended to accurately <br />reflect the approved plan. <br />