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2. The Dl vision proposes to approve the use of clean straw or native hay mulch as a means to meet soil stabilization requirements (4.15.4). 3. Methods to measure herbaceous cover and production, species diversity, and woody plant density are discussed in 3.5.9 Volume I. These techniques include comparison of reference area and affected area. The Division proposes to approve of these techniques (4.15.7(1)). 4. Comparisons between reclaimed and undisturbed areas, in order to demonstrate that success criteria of 4.15.8, 4.15.9, or 4.15.10 have been met, will be based on the following: cover, productivity, diversity, and woody plant density (Rule 4.15.7(2)(d)). The Division proposes to approve the basis for this comparison. 5. The reference areas will be utilized to determine revegetation success in a manner which the Division finds acceptable 4.15.7(4)). 6. The Division finds that a lower standard is appropriate for cover and/or production in woody vegetation communities as explained above (4.15.8(3) and (4)). X. Protection of Fish, Wildlife and Related Environmental Values - f Section 4.6 of Volume I, Appendix 1 of Volume V and Section 4.5 of Volume VI of the application contain the fish and wildlife information pertaining to Munger Canyon. The applicant has supplied the results of a site-specific wildlife study, along with materials compiled from other studies. The area which the mine is located in has been identified as mule deer winter range. Mule deer tend to migrate diffusely from upland to lowland areas in the winter time. This results in higher concentrations of deer in the canyon bottoms during the winter. At the time of issuance of the initial five-year permit, The Colorado Division of Wildlife, U.S. Fish and Wildlife Service and the Bureau of Land Management expressed some concerns relative to wildlife issues at the Munger Canyon Mine. These concerns were: 1> the adequacy of the raptor survey in the permit application, 2) the documentation of road kills in the vicinity of the mine, and 3) the presence of mule deer critical winter range in the vicinity of the mine. Additional raptor information was gathered by the applicant on July 20, 1983 in response to Stipulation No. 15 of the initial permit. Stipulation No. 15 required the applicant to conduct raptor surveys during the summer of 1983 and 1984 and submit survey results to the U.S.F.W.S. and the Division. Following completion of the first survey, the need for an additional survey was waived by the U.S.F.W.S., based on a determination that the data base obtained during the initial -41-