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Colowyo Mine <br />TR-72 PAR3 <br />29 January 2009 <br />Page 7 of 8 <br />26. In the 26 June 2008 letter, the Division requested narrative clarification regarding the <br />distinction between "evolved" and "targeted" sagebrush steppe, with respect to applicable <br />cover and production standards and success demonstration specifics. The requested <br />information was provided and the amended narrative on pages 4.15-15 through 4.15-17 is <br />acceptable, with one exception. On amended page 4.15-17, under Herbaceous <br />Production, the revised language indicates that post-2008 sagebrush steppe revegetation <br />areas would not be subject to herbaceous production success criteria. This change was <br />made based on anticipated state rule changes that have not yet been finalized or submitted <br />for approval. The change to eliminate the production standard cannot be approved in the <br />permit until the pertinent rule change is approved. <br />Please revise the narrative section regarding herbaceous production criteria for <br />post-2008 sagebrush steppe revegetation to comply with current regulations. <br />27. Item Resolved in first adequacy review. <br />28. Item Resolved in first adequacy review. <br />29. In the June 2008 letter, the Division requested revision of the diversity criteria for <br />wildlife habitat to specify the minimum relative cover component to be represented by <br />native* perennial forbs. The section was amended to address our concern, but it appears <br />that the proposed standard could be still be interpreted to allow for the diversity criteria to <br />be met without any forb contribution (the Division does not believe this was intended). <br />For clarity, the Division requests that the standard be re-worded as follows: <br />• At least four native* perennial herbaceous species, each more than 3% <br />composition, minimum two of which are grasses and minimum one of which is <br />a forb, with the following caveat; <br />If no single native* forb species exceeds 3% composition, the forb requirement <br />can be met if: <br />a) at least two native* perennial forbs combined comprise at least 2% <br />composition, or; <br />b)at least four native* perennial forbs combined comprise at least 1% <br />composition. <br />30. Item Resolved in first adequacy review. <br />31. Colowyo has amended the text on pages 2.05-61 and 4.15-3 as requested. While there is <br />still some leeway in the plan, as written, the Division understands the need for flexibility <br />in such a plan. The Division considers this Item Resolved.