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See New Comment 19, regarding erroneous Tab 22 'Table of Content Page numbering. <br />See New Comment 20, regarding question why production standard for NH-1 mine areas <br />is based on a technical standard rather than reference area comparison. <br />2. This comment also pertained to reference area status and location for NH-1 mine areas. <br />Please refer to requested Map 22-•2 map clarification in item 1, above. <br />3. OMLR had pointed out discrepancies between current findings of compliance narrative <br />and Permit Application Package (PAP) information regarding species diversity criteria <br />applicability to NH-1 Dryland Pasture reclamation areas. Table 22-5 and associated <br />narrative was amended to clarify that the diversity standard for NH-l is applicable only to <br />Rangeland areas, not to Dryland Pasture areas, which is consistent with the narrative of <br />page 32 of the findings (and also consistent with success standards for NH-2 Dryland <br />Pasture). Item Resolved. <br />See New Comment 21, regarding the need for quality (e.g. species or life form composition <br />criteria) applicable to Dryland Pasture, Irrigated Pasture, and Irrigated Cropland <br />reclamation. <br />4. OMLR had noted an alternate approach to reference area cover comparison that the <br />operator might want to consider. Operator responded that the currently approved <br />comparison approach based solely on perennial cover would be retained. Item BMbM,-. <br />5. OMLR noted that the Sample Techniques and Design section of the PAP applicable to the <br />NH-I mine areas was substantially outdated, and requested that the section be amended to <br />ensue conformance of sampling and statistical demonstration methods with Rule 4.15.11. <br />This concern was addressed by revised aM ling, T niOM MA Design section on <br />amended page 26 and 27 of Tab 22, and revised vegetation Success Criteria and <br />Staistical Procedures narrative on pages 27 through 30 of Tab 22. The revised sections <br />are in general conformance with applicable sections of Rule 4.15.11, but certain <br />clarifications appear to be warranted: <br />a) Narrative states that herbaceous production will be measured "at reclaimed areas <br />and the reference area". This does not correspond with Table 22-5, which indicates <br />that 90% of a 500 pound per acre technical standard is the production success <br />criteria for dryland pasture, for the NH-1 Area 2. Please amend the appropriate <br />sections of the narrative or the table to ensure that the PAP is internally <br />consistent. <br />See New Comment 20, regarding question why production standard for NH-1 mine <br />areas is based on a technical standard rather than reference area comparisoa <br />b) Narrative in Mp g Techniques and Design and R egetation Success C,ri,ena <br />and Statistical PFocS;dures of amended Tab 22 seems to be directed specifically to <br />success evaluation for NN-I Dryland Pasture areas. Please amend the narrative <br />WFC Exhibit 2 <br />Page 2 of 112