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component, if measures are not taken to minimize the grazing pressure. Although not evaluated in the Cedar Creek monitoring or report, cattle use may possibly have been a factor in the apparent seeding failure at the RSRDA borrow area, seeded in November 2002. At the North Decline, the significant cheatgrass component has negatively impacted establishment of seeded perennial grasses, forbs, and subshrub species. The consultant's report included several recommendations for the operator to consider, which would need to be addressed within a revision to the permit application. In general, we concur with the concerns identified in the report, but we feel that alternative remedial approaches may warrant consideration, prior to submittal of a revision to the reclamation plan. Our comments in regard to recommended modifications and remedial treatments are set forth below. The report notes that the approved diversity standard includes the criterion that No reclaimed area shall have a single species that represents greater than 70% relative cover. The narrative further notes that "...the ubiquitous and invasive annual grass, cheatgrass (Anisantha tectorum), has relative cover values approaching or surpassing 70% in years favorable to growth in both the North Decline Area and Greasewood Reference Area". This is the case, and in fact it is likely true of a high percentage of the rangeland in the permit area and vicinity, particularly along the valley bottoms with an open greasewood overstory. Cedar.Creek recommends that the standard be modified to read No rec/aimed area sha// have acing/e anted species that represents greater than 70% relative cover. Cedar Creek's reasoning is that the original intent was to preclude a planted monoculture where one species is overwhelmingly dominant. We would agree that planted species were the primary consideration, but we feel that it would be inappropriate to alter the standard in such a way that would allow for an invasive annual grass to become more pervasive on reclaimed areas than on• similar undisturbed adjacent areas. Although cheatgrass does havevalue for grazers and certain birds during specific seasons, and is the dietary staple fot chukar partridge, a . locally important game bird, a diverse community including a variety of lite forms provides better year around habitat for a wider variety of species. We would recommend the following modification: No reclaimed area shall have a single species that represents greater than 70% relative cover, with the exception of annual grasses. Annual grass species, singly or in the aggregate, shall not exceed 70% relative cover, unless the aggregate relative cover of annual grasses in the corresponding reference area exceeds 70%: In such instances, re/ative cover of annua/ grasses in the reclaimed area shall not exceed the relative cover of annual grasses in the reference area. 2. Sampling data indicated a high cheatgrass component and very low perennial herbaceous component at the North Decline. Cool season grasses are a minor component and warm season grasses, perennial forbs, and subshrubs are essentially absent from the stand. The late sampling date could possibly have under- represented ephemeral fobs, and to a lesser extent, cool season grasses, but based on Division observations in recent years at various times of the year, we believe the data provide a fairly accurate representation of the composition of perennial species and annual grasses. We concur that remedial measures are warranted, to reduce the cheatgrass competition and increase the perennial herbaceous component, particularly warm season grasses and perennial forbs/subshrubs.