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a o The applicant should verify, as required by Section 4.15.2of the Colorado permanent regulatory program, that adapted strains of the revegetation species will be used when available. Specific strains to be used should be included with the requested seedmix information. o The paired reference site - affected site method employed to demonstrate comparability between reference areas and corresponding vegetation types does not appear to meet the requirements of Section 4.15.7(3)(b)of the Colorado permanent regulatory program. One sample cluster of approximately 1.2 acres does not characterize the dvariability of herbaceous cover and production, and woody plant density of an entire affected community. For a discussion of procedures for determining sample adequacy with a cluster sampling scheme, the section of the Wyoming DEQ Vegetation Guidelines on Two Stage Sampling would be appropriate. o An evaluation of sample adequacy is required for herbaceous production and woody plant density, and is not limited to cover alone, as indicated on page II. F -10. Table 15 is labeled "Production Cover Sample Efficien- cy". Please clarify. o The request for a variance from the woody plant density requirement on page V -52 is not specific regarding location and acreages of the areas involved. A specified lesser density should be proposed and any potential adverse impacts on wildlife evaluated as required by Section 4.15.8(7) of the Colorado permanent regulatory program. The application should propose alternate criteria for the evaluation of revegetation success on these sites. o A detailed discussion of the methods and materials that will be used to control pests and weeds during reclamation should be included in the application (it should be noted that the use of pesticides and herbicides requires the approval of the regulatory authorities). -15-