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Please provide amended narrative in Section 4.15.7 and 4.15.8 of Volume 1, to describe which <br />areas of the reclaimed landscape will be compared using weighted average comparison, with <br />relevant reference areas and weighting factors defined (presumably original permit area <br />grazinglands would be compared using appropriate weighting of the sagebrush and mountain <br />shrub reference areas, and South Taylor expansion area grazinglands would be compared using <br />appropriate weighting of the sagebrush, mountain shrub, and aspen reference areas). In addition, <br />the narrative should be amended to state which areas of the reclaimed landscape will be compared <br />solely to the sagebrush reference area, with appropriate justification (presumably sagebrush <br />steppe targeted areas of post-2008 reclamation in both the original permit area and the South <br />Taylor expansion area). The subject areas should be delineated on appropriate postmining <br />map(s) that define original permit area grazingland, original permit area sagebrush steppe, South <br />Taylor grazingland, and South Taylor sagebrush steppe. Any contradictory narrative in Volume <br />12 or other sections of the permit application should be revised to correspond with or to reference <br />the Volume 1, Section 4.15.7 amended narrative and relevant maps. <br />Adequate justification has been provided to demonstrate why use of the Sagebrush Reference <br />Area individually for comparison to sagebrush steppe targeted reclamation sites is appropriate, <br />but such justification has not been provided for comparison of grazingland reclaimed areas to any <br />particular individual "targeted" reference area. <br />Colowyo's Response: <br />Comment noted - corrections to text made as appropriate. <br />However, the Division's request for mapping of where grasslands and sagebrush steppe <br />communities will eventually occur is an impossibility. There will be sagebrush encouraging procedures <br />implemented across all reclaimed landscapes in post-2008 reclamation. Only nature will decide where <br />sufficient density of sagebrush will eventually evolve after 10 years that in turn will allow mapping of <br />sagebrush steppe communities that will then be subject to one-on-one comparisons with the sagebrush <br />reference area. Map 44 has been produced to give the Division insight into Colowyo 's thought process <br />in the initial identification of areas exhibiting < 10% slope. This is a starting point for evaluating <br />practical and prudent locations from a hyrological and biological standpoint for sagebrush steppe <br />habitat establishment efforts. <br />26. It is not clear that the proposed reduction of the herbaceous cover and production standards from 90% of <br />reference area mean to 70% of reference area mean would be warranted for sagebrush steppe <br />revegetation areas, even given the seedmix adjustments and other practices that will be implemented to <br />favor woody plants. The Division will need to assess the proposal in more detail before making a <br />determination. As noted in the narrative, levels of herbaceous cover on past reclaimed areas at Colowyo <br />have exceeded the premine condition by 30% to 50%. Given the episodic nature of sagebrush <br />establishment observed in northwest Colorado and documented in the literature for big sagebrush, <br />compared to the more consistent and reliable establishment of grasses, it may be reasonable to assume <br />that an herbaceous cover equivalent to 90% of the sagebrush reference area herbaceous cover (30.17% <br />cited) would become established within a relatively short time frame, particularly given the allowance <br />for interseeding of native grasses and forbs during the early years of the liability period. <br />Herbaceous understory cover is important to provide quality habitat for sagegrouse and other species, as <br />well as to provide adequate soil protection. 70% of a reference area mean of 30.17% would be 21%