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Annual Bevegetation Rebort The revegetation report war ar always thorough, extensively documenter~ and well presented The relatively stable woody plant density for the 1996 area and the dramatic increase in woody plants in the 1999 anal is quite encouraging, with the sample mean for both areas of over 700 stems per acre. We have the fo!/awtng rpecifzc questions and comments. 6. The report references a woody plant density standard of 1000 stems per acre for the mine areas sampled However, the permit ru»zntly specifier an averadl standard of 450 stems per acre, with a standard of 2000 stems per acre within concentrated planting areas. The repoK doer not indicate which, tf any, of the woody plant density quadrants fell within concentrated planting areas, to which the higher standard would apply. Please identify the woody plant density quadrants, if any, which fell within concentrated woodyplanting areas. Response: The transects were not surveyed or located other than in general terms so the ones which fell in shrub plots aze impossible to detemrine. 7. Text page 6 erroneously indicates that native perennial forbr contributed 20.4% relative cover in the 1996 reclaimed area, and references titer milkvetch and alfalfa ar the dominate native forb. As correctly noted in later sections of the report, alfalfa and titer milkvetch are int~nduced for~ir. Please amend the page 6 text as appropriate. Cicer milkvetch war not listed in the approved reedmix in 1996. l~liat is the likely explanation fonts significant presence m the 1996 parcels (4% relative cover in 2000 and 14% in 2003)? Response: please insert the attached revised page 6 in your copy of the 2003 Revegetation Monitoring Report. The 1996 pazcels were mistakenly seeded with an unlabeled bag of seed from the Seneca II site where titer 8. The rzpaY narrative and ftguter parent information comparing cover, producZian, and woody plant density valuer far 1996 and 1999 revegetated areas against permit standards. Thu tnforntation it valuable, and allows forprojection as to status of revegetation with respect to potential for meeting ftnal band release standards, and possible defzctencies. Potential for meeting bond release standards for cover, production, and woody plant density would appear to be high, with the exception that woody plant density within concentrated planting areas war not spectfzcally asserted The Division hat requested ~n the cu»znt midterm permit review) that this issue be assessed in the 2004 annual revegetation report. Data, fzgures, and discussion elated to species diversity and composition wen presented in the report, however there war no specific comparison of reclaimed area specter diversity against approved permit standards. The cu»zntly applicable diversity standard for the original permit"portions of the II-W permit area it a rigorous relative cover based standard that requires: • 3 cool reruon (perennial?)gran rpecze s>3% relative cover each • 3 (non noxious) forb species >3% relative cover each • At least 4 rhrrtb species; 2 of which exceed 1 % relative cover over-all • In conrentrated planting areas, 2 shrub rpeciey each exceeding 3% relative cover • At least 1 the species, exceeding 1 % relative cover within concentrated planting areas • Na single specter shall exceed 40% relative cover • Combined 3 cool reasongrasses, 3 forbr, 2 shrubs, and 1 the shall not exceed 75% relative cover Based on our interpretation of the standard as applied to the data, both the 1996 and 1999 reclamation areas would fail to meet the diversity standard because there were no shrub pecier that comprise at least 1 % relative cover over-all (despite over-all woody plant density levels that appear to meet the applicable standard). In both carer, there war no information provided regarding mrrrpGance with woody plant relative cover standards `nathtn concentrated planting areas': Ako, then were no tree specter documented in any of the sampling data.