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species, cheatgrass and tumble mustard. -wlat~gy~p,`e,~ge~' ] s c - e is d.e" c.• Y~t~h?e7h''e~r~ran~,T~_ a~-r_n_ ~,x_ ~r;~o~n'~(~ d'a~d:was a ~ e o^ t?h ee o o n o _ o e o ~ so ~L+h`~e+r}a o With respect to vegetation cover, o o~e~pe);otrk(~N~2+)~o~ame~ - o fo eelt~n"cj~9I01g'~b7f~tat7.e e . , • ~~ e~~at7~id~a~~dR4fo~.eWt31~d§.9g - igure 4 in the report is misleading, because the reference area cover value of 11.9$ depicted on the bar graph excludes shrub cover. Perennial forbs are essentially absent from the stand in any of the test plots as well as the refuse area as a whole, and shrubs are present in extremely low numbers relative to the reference area density. The early successional nature of the refuse area vegetation makes it difficult to reach a sound conclusion regarding adequate cover depth for successful revegetation, since "successful revegetation" has not yet been achieved on any of the cover depth test plots or other portions of the refuse pile. The generally poor perennial establishment may be related to drought during the first few years after seeding. The dense growth of cheatgrass and tumble mustard on portions of the refuse area this year is probably attributable to the relative sparsity of perennial vegetation, combined with the abnormally wet spring and early summer. Some additional observations with regard to vegetation include: Only one true forb (Utah sweetvetch) was included in the seedmix, along with the half-shrub winterfat, which could be counted as a forb with respect to the diversity standard. If this seedmix is still included in the permit, the operator should consider adding additional adapted forbs, such as globemallow, small Burnet, Palmer penstemon, etc. The seedmix listed in Table i provides for a seeding rate of 20 PLS seeds per square foot, which is approximately 1/2 of the commonly recommended seeding rate for critical sites. Why was this low seeding rate employed? If this mix is still included in the permit it should be increased appropriately. Woody plant density was reported as #/600 sq.meters, which is something of an odd reporting unit, since the individual plots were 900 sq. meters. Why was this unit used? Also, woody plant density summary data was presented in Table 2, but the transect data with woody plant numbers by species was not provided. This data should be included. The reference area woody plant density of 532 stems/600 sq. meters converts to approximately 3,600 stems per acre, which may be quite difficult to achieve in a reasonable time period and is a substantially higher standard than most coal mines in Colorado have been required to meet. The operator may wish to consider requesting a reduction in the standard.