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Page 2 of 3 <br />perennial forage forb species. No single species ivi71 contribute Ivor e than <br />60% relative cover. <br />In Section 2.05.4(2)(e), page 28, WFC requests that the diversity standard for dryland pasture <br />be waived. The diversity standard is required by Rule 4.15.8 (5). The Division does not have <br />the authority to waive the diversity requirement. Please remove the "request for the diversity <br />standard to be waived from the PAP on page 2.05.4(2)(e) -28 and replace the species diversity <br />standard with the Division's suggested standard above. Please note that the shrub density <br />standard can be waived because the post - mining land use is not wildlife habitat. <br />2. Item Resolved: <br />3. Item Resolved. <br />4. Item Resolved. <br />5. Items 5 -14 previously resolved. <br />15. This comment was asked in Brock Bowles' memo dated January 26, 2011 which was given to <br />WFC in the February 11, 2011 meeting at the DRMS Denver office. Specifically, the comment <br />stated, "Section 2.05.4(2)(e), page 10 — Attachments 2.05.4(2)(e) -1 Irrigation Design and <br />Application Rates and 2.05.4(2)(e) -2 [NRCS recommendations] are not in the PAP. Please <br />submit a copy of each of these to the Division The NRCS recommendations have been <br />submitted but the irrigation design and application rates have not. Please provide those or <br />provide a commitment in Attachment 2.05.4(2)(e) -1 stating that the irrigation designs and <br />application rates will be submitted as a technical revision to the permit prior to backfilling and <br />grading of the irrigated lands. <br />Rule 2.05.4(2)(d) — <br />1. Item Resolved. <br />2, Item Resolved. <br />3. WFC feels that revegetation success criteria can be met with a single lift topsoil removal plan <br />and the Division finds that there isn't supporting evidence to prove whether a double lift <br />removal of topsoil is more advantageous over a single lift for revegetation of non -prime <br />farmland. Therefore, a single lift topsoil removal plan will be approved. Item Resolved. <br />Rule 2.05.4(2)(e) — Reve2etation Plan <br />A "Historic Record" method will be used for Intensively Managed Irrigated Pasture (IMIP)` <br />areas. As discussed in Section 2.04. 10 pages 33 -34, the IMIP areas were sampled for three <br />consecutive years and the mean plant cover and production values will be used as the <br />