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s <br /> reclaimed areas other than CRDA No. 2 and No. 3 which include areas <br /> of designated "shadscale" and "greasewood" vegetation. It is <br /> recommended that consideration be given to eliminating the <br /> "Greasewood/Shadscale Permanent Seedmix" and adopting the "Cameo <br /> Refuse Disposal Area Nos. 2 and 3 Seed Mix" as the permanent <br /> seedmix for all reclaimed areas at the mine. <br /> b) On page 192 , it is indicated that dozer tracking up and ow <br /> down steep slopes may be used after seeding to better incorporate <br /> the seed. It is important that some mechanism for covering seed gv <br /> always be a component of the revegetation sequence on steep slopes. <br /> The text should be revised to specify that dozer tracking or other <br /> specified measures will be employed to ensure seed coverage on <br /> steep slopes. <br /> c) On page 192a, more detailed information should be provided <br /> regarding application rate for the various mulches and type and <br /> amount of tackifier which may be employed. The one ton per acre <br /> mulch rate listed is 1/2 the standard application rate for straw or <br /> hay mulch, and it should be revised or some justification for the <br /> low application rate should be provided. Revegetation <br /> specifications for the lower benches of CRDA No. 1 and No. 2 are <br /> provided on page 195d. The same degree of detail should be <br /> provided for other reclamation areas. <br /> 4 . We have the following concerns with respect to demonstrations <br /> of revegetation success: <br /> a) There are apparent contradictions among various sections <br /> of the application concerning success criteria for cover and woody <br /> plant density. Page 194 indicates that the cover standard would be <br /> based on either herbaceous cover or herbaceous cover plus cover of <br /> woody plants less than . 5 meters in height. Page 195aIindicates <br /> that herbaceous cover would be the applicable criteria. With <br /> respect to woody plant density, Page 195 indicates that-shrubs to <br /> be counted would be limited to those greater than .5 meters in <br /> height, but the height cutoff is not specified on Page 195b. On <br /> Page 4 of Appendix SS, the 1992 baseline vegetation survey, it is <br /> stated that the study was conducted as proposed by the operator, <br /> and modified by the Division, "except that ( 1 ) total vegetation <br /> cover contrasted to herbaceous cover was determined; (2) shrub <br /> density was determined by counting all individuals present, not <br /> just those greater than 0. 5 meters in height. " <br /> Some revision of the applicable sections of pages 194-195b would <br /> appear to be warranted for clarification and consistency. Based on <br /> the methodology and approaches followed in the baseline survey as <br /> agreed to by the Division, it would appear that total vegetation <br /> cover, rather than herbaceous cover, and total woody plant density, <br /> rather than woody plants greater than . 5 meters in height, should <br /> be listed as applicable criteria. <br /> b) The sample adequacy formula referenced on page 194 would <br /> be appropriate for reference area sampling, with minor <br />