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Annual Bevevetation Aebort The revegetatian report was as alwayr thorough, exten rivedy documented, and well parented The alatively stable woody plant density for the 1996 area and the dramatic increase in woody plantr in the 1999 areas is quite encouraging, with the sample mean for both agar of over 700 Hems per aca. We have the fallowing specific guertionr and comments. 6. The report referencer a woody plant denrity standard of 1000 rtems per acre for the mine areas sampled However, the permit currently specifier an overall standard of 450 stems per aca, with a standard of 2000 stemr per acre within concentrated planting areas. The report does not indicate which, if any, of the woody plant density quadrants fell within concentrated planting areas, to which the htgher standard would apply. Please idena`fy the woodyplant density quadrants, if any, which FeU within concentrated woody planting areas. Response: The transects were not surveyed or located other than in general terms so the ones which fell in shrub plots are impossible to determine. 7. Text page 6 erroneously indicates that native peannial forbs contributed 20.4% alative cover in the 1996 ac/aimed area, and references titer milkvetch and alfalfa as the dominate native jorb. As correctly noted in later sections of the report, alfalfa and titer milkvetch are intmducedforbs. Please amend thepage 6 text as appropriate. Cicer milkvetch was Hat listed in the approved seedmix in 1996. What is the likely explanation for its signi&cant presence in the 1996 parcels (4%telative coverin 2000 and 14% in 2003)? Response: please insert the attached revised page 6 in your copy of the 2003 Revegetadon Monitoring Report. The 1996 parcels were mistakenly seeded with an unlabeled bag of seed from the Seneca II site where ricer milkvetch is approved. 8. The report narrative and fzguar preseut information comparing cover, production, and woody plant density valuer for 1996 and 1999 avegetated areas againstpermit standards. This information is valuable, and allows forprojection ar to rtatur of avegetation with repect to potential for meeting final bond releare standardr, and possible deficiencies. Potential far meeting bond release standards for cover, production, and woody plant denrity would appear to be high, with the exception that woody plant density within rnncentrated planting arear was not specifrcally asrerred The Division bas requested (in the current midterm permit review) that this irsue be arressed in the 2004 annual revegetatian report. Data, figurer, and dzicussion related to species diverrity and composition were parented in the report, however there war no specific comparison of reclaimed area species dfverrity against approved permit standards. The currently applicable diversity standard far the `original permit "portions of the II-W permit aaa zr a rigorous alative rover bared staudard that requiar: • 3 cool reason (perennial?)grass specie s>3% alative cover each • 3 (non noxious) faro species >3% relative cover each • At leant 4 shrub species 2 of which exceed 1 % relative rover over-all • In concentrated planting areas, 2 shrub species, each exceeding 3% relative cover • At least 1 tae species, exceeding 1 % relative cover within concentrated planting areas • No single species shall exceed 40% relative cover • Combined 3 cool season grasser, 3 faros, 2 shrubs, and 1 tae shall not exceed 75°/v relative cover Bared on our interpretation of the standard ar applied to the data, both the 1996 and 1999 reclamation aaas would fail to meet the diversity standard because then were no rhrxrb species that comprise at least 1 % alative cover over-al! (despite over-all woody plant density levels that appear to meet the appls~cable standard). In both cares, there was no information provided agarding compliance with woody plant relative cover standards `within concentrated planting areas': Also, rhea were no tae species documented in any of the sampling data.