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smooth Brame, which dominated the site early in the liability period, appears to have died aut? <br />Alfalfa also appears to have largely disappeared, and perennial grasses other than Russian <br />wildrye are miner components, The extent to which the irrigation practices may have contributed <br />to the relatively pear stand observed is unknown, but at a minimum it seems likely that the <br />irriga#ion migh# have enhanced the grown of smoo#h biome earl?r ire the liability period, at #?re <br />expense of mare draught adapted species. <br />? . Narrative in the second paragraph of p. 22-? D of the NH?? permit application package <br />{PAP}, indicates that the upland sagebrush reference area in the vicinity of mining areas <br />? and is the only reference area that exists for the Nucla Mine. This statement is <br />apparently outdated; a reference area an airport property was approved in ?aaa to <br />replace the sagebrush reference area. Pieces amend the page ??-1 a text to clarify <br />that the sagebrush reference area has been replaced in by a reference area on the <br />NuelalNaturita airport property. <br />?, Narrative on p. ?- ? ? through 2?-? 5 of the NH- ? PAP, and Exhibit ??-2 on p. 2?-? ? are <br />also outdated, as the reference area lacatian has been relocated from the area described <br />{BLM property west of the airports to inside the forked airport praperky. Please amend <br />the text and Exhibit as appropriate. <br />?. Table 2?- an p? ??-? 7, and text an page ?Z-?, of the NH-? PAP indicates that a species <br />diversity standard of three perennial grasses, with each providing at least 3°la relative <br />cover, applies to the NH•? dryland pasture areas. This conflicts with narrative on page <br />2 of the Division's March 18, ?gD Proposed Decision and Findings of compliance <br />{?99? findings document}, which states that species diversity standards do not apply #a <br />dryland pasture reclamation. Please address the discrepancy. if the Divisson <br />approved a waiver of the diversity standard, please reference the applicable <br />revision action and amend the fable ?-? accordingly. <br />4. vile Hate that Table ??-5 indicates that the cover standard applicable to Nl?-? dryland <br />pasture reclaimed areas is "D°lo of the live perennial cover of dryland pasture reference <br />area". VU would paint cut that applicable regulations in 4.15.5 da not specify that caner <br />success demonstration necessarily be based solely an perennial vegetation. Narrative <br />under Item 3, paragraph ?, p.1 ?, of the Division's April 1995 bond release guideline <br />dacur?ent, addresses the extent to which annual and biennial species ray be allowed #o <br />contribute toward demonstrations of success, <br />the allowable relative cover and production can?ribution of annual and brer?nial species sliacrld riot <br />exceed ?? percenf, ar the relative caner and productforr of such species In fhe associated reference <br />area or standard, whichever is f?Jgher. Ar?r?r?al ar biennial cover orpmductior? i? excess of phis <br />threshold should be deleted ?rarrr fire reclaimed area data prior to success corrfparison, An <br />acceptable al#emafive rs to delete all arrr?uallbierrnral cover arrd prad?ctlorr from ,both reference area <br />and reclaimed area data prior to success comparison. <br />1NF? may wish to consider proposing an amendrr?ent to the specified criteria, to <br />allow far inclusion of an annual?biennial componentforsuccess demanstratian. <br />?, The sample Techniques and Design section of the NH-? PAP, p• ??-?? through ??-?5, is <br />somewhat outdated, containing outdated references to data collection in 1999 and ?gQO <br />and the sagebrush reference area, and also reference to sample adequacy and <br />hypothesis tasting formulas in the 1995 guidelines document. specific sampling <br />timeframes mentioned may be overly restrictive; June through September sampling <br />window would allow sufficient flexibility to caardinate sampling with growing conditions in <br />a given year, sections of the guideline addressing statistical methods have been