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1981". Map l8 delineates which of these areas are pre-law, those areas seeded prior to <br />August 3, 1977. Vegetation cover is the only standard for success on pre-law areas and <br />the permit can be revised to reflect pre-law standards. Reference area standards for cover <br />and production apply to the interim lands plus the approved permit standard for species <br />diversity (page 816-157bb) and woody plant density (2,000 stems/acre). <br />I5. Rule 4.15.7 requires the revegetation plan to set foRh revegetation success standards, <br />measurement/sampling methods and statistical tests of success. Kerr's revegetation <br />success standards in Section 816.116(a) state that a reference azea will be used combined <br />with baseline data for the Salt Flat vegetation type where appropriate. Kerr has <br />established four reference areas to reflect the pre-mining vegetation communities. <br />Revegetation will be deemed successful when it is comparable to the "relevant" reference <br />area. How is Kerr going to establish which is the relevant reference area? <br />The revegetation success standazds need to be reevaluated. The current permitted <br />standazd for revegetation references a 1980 OSM guideline (Lazsen, 1980) and is too <br />general. A detailed plan for bond release demonstrations of revegetation success should <br />be provided including sampling design (addressing which reference area will be used for <br />each reclaimed azea), methods for sampling cover, production, woody plant density and <br />species diversity, and statistical methods, including sample size adequacy evaluation and <br />tests of success. In developing your proposed standards, Kerr should reference the <br />Division's "Guidelines for Compliance with Land Use and Vegetation Requirements" <br />(October, 1988) and "Guideline Regarding Selected Coal Mine Bond Release Issues" <br />(April 18, 1995). <br />Marr Strip Mine, C-80-006 10 September 16, 1998 <br />Midterm Review Fourth Permit Tetnt <br />