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24. The statement in Section 4.15.4 indicating that Colowyo currently does not utilize contour furrows on reclaimed slopes does not correspond to narrative under "Topsoil Redistribution Plan" on amended pages 2.05-46 and 2.05-47, nor to the statement on amended page 2.05- 59 indicating that, without use of a mulch, erosion control has been maintained with surface manipulation methods such as contour furrows, drainage benches and permanent drainage channels. Please revise the various narrative sections as appropriate, and to be internally consistent. Given the relatively long steep slopes depicted in the postmining topography for portions of the South Taylor revision area, some combination of mulching and surface manipulation methods would appear to be warranted. 25. There is a lack of clarity in amended Section 4.15.7 and 4.15.8 regarding which areas of the original permit area and which areas of the South Taylor expansion area would be compared using a single specified reference area (the sagebrush reference area), pursuant to Rule 4.15.7(4)(a), and which areas would be compared using the weighted average approach with multiple reference areas, pursuant to Rule 4.15.7(4)(b). In Section 2.10 of the original application, and Sections 2.10 and 4.15 of the South Taylor revision Volume 12 (submitted in PR-2), narrative states that that the weighted average approach would be used for the original permit area (using the sagebrush and mountain shrub reference areas), and that a "targeted reference area" comparison, using only the sagebrush reference area would be used for the South Taylor expansion area (due to focus on reestablishment of sagebrush grassland habitat in the expansion area). Text in amended Section 4.15.7 and 4.15.8 of Volume 1 conflicts with the Volume 12 narrative cited, and lacks the necessary clarity. Please provide amended narrative in Section 4.15.7 and 4.15.8 of Volume 1, to describe which areas of the reclaimed landscape will be compared using weighted average comparison, with relevant reference areas and weighting factors defined (presumably original permit area grazinglands would be compared using appropriate weighting of the sagebrush and mountain shrub reference areas, and South Taylor expansion area grazinglands would be compared using appropriate weighting of the sagebrush, mountain shrub, and aspen reference areas). In addition, the narrative should be amended to state which areas of the reclaimed landscape will be compared solely to the sagebrush reference area, with appropriate justification (presumably sagebrush steppe targeted areas of post-2008 reclamation in both the original permit area and the South Taylor expansion area). The subject areas should be delineated on appropriate postmining map(s) that define original permit area grazingland, original permit area sagebrush steppe, South Taylor grazingland, and South Taylor sagebrush steppe. Any contradictory narrative in Volume 12 or other sections of the permit application should be revised to correspond with or to reference the Volume 1, Section 4.15.7 amended narrative and relevant maps. Adequate justification has been provided to demonstrate why use of the Sagebrush Reference Area individually for comparison to sagebrush steppe targeted reclamation sites is appropriate, but such justification has not been provided for comparison of grazingland reclaimed areas to any particular individual "targeted" reference area. Colowyo Coal Company, C-1981-019 TR-72 April 29, 2008 Page 12