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issue. This concerns the area of species diversity and woody plant density. The success standards for species diversity at the Southfield Mine is adequate when; the four dominant species, based on plant cover, comprise no more than 80$ of the total species composition. No one species shall comprise more than 40$ of the total species composition as determined by plant cover. The author apparently has a problem with this stating that baseline data was not taken into account when developing this "arbitrary" standard. This may in fact be partially correct. However, if baseline data was used one specie(Blue grama) would need to account for over 50$ of the reclaimed cover or maybe two warm season species would need to account for 50+$ of the cover. This standard was probably created with the understanding that the final species composition would probably not reflect the baseline data given the seed mix approved. In any case the operator would be deficient with their current data since both dominant grasses are cool season species. The standard in place is actually fairly lenient and allows more flexibility than if we were to go strictly by the baseline data. The only reason the author is questioning this standard is that one specie (western wheatgrass) is nearly to the threshold limit of 40$ of the total cover. This standard is very achievable and will provide for a good permanent, diverse vegetative cover. If they insist on revising this standard, I'm sure we could accommodate them but the new standard will include a lot more warm season species, an area where they are currently deficient. The woody plant density success standard is also brought into question in this report. The current standard is a bit unclear in that a direct count of shrubs on the reclaimed area is to be compared with a similar count on the reference area. The unclear part is that a "t-test" would be utilized to evaluate data equivalence. This is not necessary if all shrubs are being counted(essentially a census).This section should be revised to state that woody plant density will be successful if the woody plant density on the reclaimed area is 90$ of the reference area, or if true sampling is conducted it should be 90$ of the reference area with 90$ statistical confidence. There really should be no confusion about what is or is not considered a woody plant. The Division's vegetation guideline clearly states that subshrubs or half shrubs are not to be included. The guideline specifically identifies Artemisia fridiga, Artemisia ludoviciana, Ceratoides Janata, Xanthocephaluna sarothrae, and Yucca glauca as half shrubs or (suffruticose) species. All cactus should also be included in this group. None of these are to be considered woody plants for the purpose of meeting woody plant densities. Given this fact, woody plants were hardly encountered during sampling. This should not present a problem since success is based on reference area comparisons. One point which should be mentioned is that Southfield has committed to planting live seedlings at a rate of four trees and