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Seeding of the disturbed areas will be done in the Fall following the placement of topsoil and seeding of a stubble mulch (page 58, Vol. 1 of the permit application). This is the favorable planting time for the seed mix used. Regraded and topsoiled areas will be planted with a stubble- mulch of winter rye. Additional straw mulch will be added as necessary to control erosion. Following seeding of the permanent seed mix, a mulch of wood chips will be applied at a rate of 80 yd3/acre (page 64, Vol. 1 and Exhibit 1 of the permit applica- tion). Wyoming Fuels proposes to allow grazing of the reclaimed areas during the last two years of the liability period (page 16, Addendum I of the permit application). However, the applicant has not supplied a method to determine when vegetation is ade- quately established to withstand grazing. Furthermore, there is no plan for postmining grazing management of revegetated and reference areas. Therefore, the following stipulation is pro- posed: Within 90 days of permit issuance the applicant must submit a plan for revegetated area and reference area post-mining grazing management and the methodology that will be used to ~~ ~ `~ determine when vegetation is adequately established to with- stand grazing. Wyoming Fuels proposes to use the reference area concept to determine revegetation success. Sampling methodology will be consistent with that used to sample the permit and reference areas (Appendix F and Addenda I and II of the permit applica- tion). The applicant proposes to use the method of weighted averages to compare all reference areas to the entire revegetated area. The evaluation proposed will include an analysis of cover, productivity, and diversity on reclaimed and reference areas. However, evaluation of woody plant density isalso required for evaluating revegetation success. -94-