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Based on m understandin of the 2010 samplin as it was explained b Mr. Viert, I believe there are a <br />couple optional approaches that would be acceptable for reference area comparison success <br />demonstration. For 2010 and future success demonstrations for Mine Area 1, Option I would be to <br />compare reclaimed area cover and production data to the wei avera of SF- A and the <br />Grassland Reference Area, with the wei percenta based on the relative area occupied b the <br />sa and g rassland ve t within the Mine I area boundar prior to disturbance. <br />Option 2 would appl onl if one of the subject reference areas exhibits both hi ve cover <br />and hi herbaceous production than the other reference area. Mr. Viert suspects this ma be the <br />case for the 2010 data, but production results have not y et been determined. If this is the case, the <br />operator would have the option of demonstratin success b comparison of reclaimed area cover and <br />production solel to the "better" of the two reference areas. <br />For 2010 and future success demonstrations for Mine Area 3, Option I would be to compare reclaimed <br />area cover and production data to the combined SREF-A and SR F- data ("50/50" wei <br />Option 2 would allow for comparison of reclaimed area data solel to the "better" of the two reference <br />areas., subject to the same caveat as described for Mine I Option 2 ( one of the two reference areas must <br />exhibit hi sample mean for both ve cover and herbaceous production). <br />The reference area comparison approaches described above could be emplo with no revision of the <br />approved permit. The allowance for comparison to the sin "better" reference area would simplif <br />the statistics of success comparison., relative to the wei avera approach, but would result in a <br />more strin test of success. <br />An additional option discussed is that the operator mi choose to revise the pen -nit to specif that <br />success demonstration would be based solel on comparison to the Grassland Reference Area, g iven <br />the fact that the reclamation plan did not re wood plant reestablishment. This approach would <br />re submittal and approval of a technical revision application. The operator has indicated that the <br />do not plan to pursue this option. <br />Please let me know if y ou have an questions. <br />