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5. The introductory paragraph to the subsection titled "2.05.4(2)(e)(vi) Determining Revegetation <br />Success" contains erroneous references to regulation sections 4.15.9 and 4.15.10 that do not <br />apply to the Seneca II permit area proposed in PR -2. Please delete the erroneous references. <br />6. The third paragraph of the "Determining Revegetation Success" subsection includes an <br />unnecessary, confusing, and outdated reference to revegetation monitoring, which would be <br />conducted "in the third or fourth, ninth and tenth year following permanent seeding... ". The <br />entire first sentence of the paragraph should be deleted; interim quantitative monitoring is no <br />longer required under the approved permit, and the 9` and 10 year sampling reference is also <br />dated (current regulations allow success demonstration sampling in the final four years of the <br />liability period, beginning no earlier than year 9, as correctly noted in Appendix 13 -13 of the <br />approved permit). Please amend the narrative as warranted. <br />7. Vegetation sampling bond release blocks, sampling methods, and associated statistical <br />procedures for demonstrations of revegetation success are currently addressed in <br />comprehensive fashion within Appendix 13 -13 of the approved application package. However, <br />Subsection 2.05.4(2)(e)(vi) of the PR-2 volume, beginning with the second paragraph of the <br />subsection on page 2.05.4 -2, describes certain approaches and methods that differ substantively <br />from those specified in Appendix 13 -13, in at least two instances. The PR -2 narrative includes <br />a proposal to base success for cover and production using only the "sagebrush grassland" <br />reference area, rather than an acreage weighted comparison to "Mountain Brush/Aspen" (83 %) <br />and "Sagebrush" (17 %). Note that the current Seneca II permit does not identify a "Sagebrush <br />Grassland" reference area; for consistency the PR -2 narrative should instead refer to the <br />"Sagebrush" reference area. In addition the PR -2 proposal specifies that "all hit" herbaceous <br />cover would be used for cover success comparison rather than the currently approved "first hit <br />herbaceous cover x 2" approach. There may be additional differences between the approaches <br />currently approved in Appendix 13 -13, and those proposed in PR -2. <br />Please include an introductory narrative within Subsection 2.05.4(2)(e)(vi) of the PR -2 <br />application volume, which clearly identifies all proposed changes in sampling and <br />statistical methods that would be used for demonstrations of revegetation success, as <br />compared to the currently approved methods as set forth in Appendix 13 -13. Provide the <br />technical rationale and regulatory basis to support the proposed changes. Include a <br />statement at the beginning of the subsection, indicating that "With the exception of the <br />following specific changes, the plan presented in Appendix 13 -13 Vegetation Evaluation <br />Procedures for Testing Reclamation Adequacy for Phase ill' Bond Release, remains in <br />effect. <br />8. Please revise the "testable hypothesis statement" at the end of the Shrub Evaluation subsection <br />to be consistent with the language of Appendix 13 -3, as follows: <br />The density of full shrubs and trees will equal or exceed 90 percent of a standard of 200 stems <br />per acre in background areas and 90% of 2000 stems per acre in concentration areas. <br />Also, for clarity, please add the following sentence following the hypothesis statement: <br />3 <br />