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Based on the narrative on page 14, the mixed shrubland reference area is not representative of the area to be disturbed. The mixed shrubland in the WRDA has 38% plant cover. The WRDA disturbed area is described as asouth-facing slope in an area that has been heavily grazed in the past. The mixed shrubland reference area has 54% percent plant cover, 26% higher than the azea to be disturbed. BRL has proposed reducing the reclamation standard for the WRDA by 50%. As stated above, Rule 4.15.7(3) requires the permittee to demonstrate statistically that each proposed reference azea is compazable to its equivalent azea to be disturbed. The Division does not agree with a fifty percent reduction for the standazd. There are some alternatives BRL may want to consider. First, BRL can commit to the higher mixed shrubland reference area standard. Second, BRL has two methods by which reference azeas may be utilized as described in Rule 4.15.7(4). BRL may want to evaluate using a weighted acreage compazison. Rule 4.15.7(4)(b) states that, "a single comparison would be made between all reference areas and the entire revegetated area and would be based on the relative area occupied by each plant community in the premining surface". If this method is selected the disturbed area acreage by community type would need to be detailed. Lastly, BRL could select another well-managed mixed shrubland reference area with a southern exposure at a lower elevation. 2. Woody plant density standards have been proposed but concurrence by the Colorado Division of Wildlife is necessary before it can be considered final. Stipulation number 14 remains outstanding. BOWIE RESOURCES MUST SUBMIT VERIFICATION TO THE DIVISION THAT THE COLORADO DIVISION OF WILDLIFE CONCURS WITH THE PROPOSED PLAN CONCERNING THE WOODY PLANT STEM DENSITY STANDARD FOR THOSE AREAS TO BE RECLAIMED AT THE BOWIE NO.2 MINE. What progress has BRL made in addressing this stipulation?