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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 III Bond Release, remains in <br />effect. <br />15. 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 <br />of a standard of 200 stems per acre in background areas and 90% of <br />2000 stems per acre in concentration areas. <br />Also, for clarity, please add the following sentence following the hypothesis statement: <br />Shrub concentration areas are depicted on Exhibit 13-13.3 in <br />Appendix 13-3. There is a single shrub concentration area of <br />approximately 6 acres within the southwestern corner of the PR-2 <br />reduced permit boundary. <br />2.05.5 <br />16. The subsection "Postmining Land Use Management" in Tab 13 of the current P.A.P. appears to <br />be somewhat out of date, with particular respect to livestock grazing management. Please <br />provide an updated narrative for inclusion in the PR-2 volume that addresses grazing <br />management within the reduced permit area, with reference to Map Exhibit 13-13.2 "Logical <br />Land Management Units", which depicts pasture boundaries. <br />17. There appears to be a discrepancy between narrative in the approved permit and narrative on <br />page 2.05.3-2 of the PR-2 volume regarding landowner requests for retention of permanent <br />fencing. The approved P.A.P. states, on page 13-38, that executed landowner requests for <br />permanent fencing will be submitted to the Division for insertion into Appendix 13-11A, upon <br />receipt. The PR-2 narrative states that fences on State of Colorado lands within the permit area <br />have been requested as permanent structures by the land owner and the grazing. leaseholder. <br />Page 5 of 7