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mines in Northwest Colorado have resulted in planting techniques that help with establishment of diverse permanent plant communities on reclaimed lands. The Division conducted a shrub establishment study in conjunction with Colorado State University, Department of Range Science, and three coal mine operators in Northwest Colorado. The study recognized the difficulties a number of operators were having establishing shrub species using traditional reclamation methods. The study initiated in 2000, eight years of observations have provided the Division, CSU and coal mine operators valuable results regarding seeding techniques that have favorable shrub establishment. Response: The results and recommendations of the referenced study have been reviewed, along with the revegetation plans presented in the current PAP. Where appropriate, the revegetation plans and seed mixtures have been modified to reflect the updated studies and recommendations. Copies of the revised PAP materials accompany these responses for insertion/replacement in the PAP. 10) The current rangeland seed mix (Table 55) and seeding method (P. 2.05-112) in the Foidel Creek permit is expected to encounter similar difficulties experienced at other locations in Northwest Colorado based upon the similarities in seed mix, environment, and seeding techniques. The Division suggests re-evaluation of the seed mix and planting methods for the rangeland areas incorporating some of the more recent study findings to assist in successful re-establishment of a diverse rangeland community that will achieve Foidel Creek Mine's reclamation success standards. Response: Please refer to the previous response to Comment 9. 11) Review of Reclamation Success determination on page 2.05-115 finds TCC refers to three reference areas, as shown on Map 18. Review of Map 18 and 18A only located two of the reference areas; R2 (Pasture reference) and R3 (Sagebrush reference). Please direct the Division to the location of the third reference area. Since R2 and R3 are located outside of the Foidel Creek permit area boundary, TCC needs to demonstrate that it still maintains control over the management of the reference areas. (Rule 4.15.7(3)(b)) Response: Reference Area R4, the Sagebrush/Meadow Reference Area, is located between Foidel Creek and Routt County Road 27, just to the west of the Foidel Creek School, as shown on Map 18. Reference Area R2, while partially outside the current Permit boundary, is on lands owned by Twentymile Coal Company (County Parcel 952071001). Similarly, Reference Area R3 is on lands owned by Twentymile Coal Company (County Parcel 952171001). 12) The Foidel Creek permit needs to state what defines reclamation success for reclaimed sites. Currently Pages 2.05-116 through 2.05-117 allude to meeting or exceeding cover, production and density, without actually stating what defines success. Please clearly define what TCC proposes as reclamation success for land reclaimed to pastureland and rangeland in accordance with (Rule 4.15.8) Response: The referenced text section has been reviewed and revised, as appropriate, to clarify revegetation success criteria for all affected vegetation types. In general, for disturbed areas corresponding to the Sagebrush Grassland and Sagebrush-Meadow vegetation types, revegetation success will be determined based on statistical equivalence for revegetation sampling (cover, production, diversity, and woody plant density) between the reclaimed lands and the corresponding Reference areas. For the Pastureland vegetation type, revegetation success will be determined in a similar manner, based on statistical equivalence (cover and production only) between the reclaimed lands and the corresponding Reference area. For reclaimed Hay Cropland, however, revegetation