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Section 816.116 (a) Continued. <br />Rule 2.05.4 (2)(e) and <br />Rule 2.15.7 <br />Revised 11/4/80 <br />For the reason of reference only, it should be mentioned that the <br />original methods for measuring revegetation success given on page <br />816-157 of the Kerr Permit application were based on recommenda- <br />tions made by both the Division and OSM at the April 16, 1980 <br />meeting between representatives of Kerr Coal, the Division and OSM. <br />The recommendation was to evaluate revegetation in terms of site <br />stabilization regarding surface erosion; this was proposed in lieu <br />of a success standard offered by Kerr Coal using arbitrary re- <br />ference areas located adjacent to the Kerr Tipple Area. It was <br />pointed out by the Division and OSM that without pre-disturbance <br />vegetation data and without topsoil to replace, the reference area <br />` concept would not apply. Kerr Coal is still taking the position <br />that the reference area concept does not apply to the tipple site. <br />Also, it should be recognized that the level of re-establishment of <br />a permanent and effective plant community, based on the proposed <br />reclamation plan, will not be altered by the method used to measure <br />revegetation success. The only concern is that the success stand- <br />ard be reasonable. <br />A review of the vegetation studies which have been performed in <br />North Park that might help establish revegetation standards was <br />made. Consideration was given to the fact that the reclamation <br />site will be topsoiled with two inches of topsoil, that it is <br />elevated above the flood plain on which it is situated and that it <br />would most resemble an upland vegetation community in terms of <br />cover, production and shrub density. Likewise, postmine landuse <br />was considered in selecting plant species and woody plant densi- <br />ties. Plant species diversity is reflected in the diverse seed <br />mixture and seedling transplants that will be used to revegetate <br />the site; however, the species diversity that will exist at the end <br />of the extended <br />816-158 b <br />