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The Division has approved the use of straw mulch at a rate of 2 tons/acre as a means to meet soil stabilization requirements. (4.15.4). The permittee has not included descriptions of revegetation success methods to measure herbaceous cover and production, species diversity, and woody plant density. A description of the techniques to be used are required by Rule 4.15.7(1) and (2). The permittee needs to submit this information and receive approval from the Division for specific methodology. As a result Stipulation No. 9 has been attached to the permit. IX. Post-mining Land Use The post-mining land use has been approved to be rangeland and wildlife habitat, which was the pre-mining land use of the affected area. X. Protection of Underground Mining In the original 5 yeaz permit term, the Division approved surface coal mining activities within 500 feet of a neazby abandoned underground mine. This previous approval was granted by the Division based on the fact that approval for such was also granted by MSHA and Colorado Division of Mines, and [ha[ improved resource recovery, abatement of water pollution, and elimination of hazards will result (4.19(1) and 4.22.4(1)). No active mining will occur during [his permit term. XI. Concurrent Surface and Underground Mining Underground mining in the permit azea is inactive and abandoned. No active underground mining is projected in [he area. XII. Operations on Alluvial Valley Floors Alluvial valley floor information may be found in permit section 2.06.8 and Exhibit II. A reconnaissance alluvial valley floor investigation for the permit and adjacent areas was conducted prior to the original issuance of the permit. The study did not find areas which could be classified as alluvial valley floors based on the criteria in Rule 2.06.8 The reconnaissance study, conducted by Panorama Resources Services Inc., evaluated [he stream valleys within Starkville Gulch, Engleville Gulch and Raton Creek. The study consisted of a review of available air photos and traversing these drainages on foot. The analysis of air photos revealed one plot of agricultural land, in the NW 1/4 SE 1/4 Section 20, T33S, R63W. This land, does not meet the criteria of an AVF. There were no areas found with unconsolidated stream laid deposits holding streams in the area. This negative finding for alluvial valley floors within or adjacent to the permit area, was further supported in a letter received from Mr. Lee A. Neve, of the Soil Conservation Service office in Trinidad, Colorado. The 20