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J ~ the site was apparently not irrigated. The application should be amended to address irrigation of the designated irrigated hayland below the terraces and the Vulcan Ditch System. Additionally, patches of several noxious weed species including Russian knapweed, field bindweed, Canada thistle, and whitetop were observed on the reclaimed area, most noticeably on the irrigated cropland portion of the reclamation. Such species are obviously incompatible with the postmine land use, and the application should be amended to include a noxious weed control plan. 2. Rule 4.15.5(1) states that "livestock grazing must not commence until one year after seeding or planting and shall be managed to promote the postmining land use." On page 4-60, the permit application states that "grazing will not be allowed until one year after seeding, and will be managed to promote the postmining land use..." On page 4-60, the application describes a perimeter fence, "which will be kept in place for 3 years, or until grazing pressure can be tolerated." At the time of my inspection, between 36 and 50 cow/calf pairs had apparently been grazing on the fenced reclaimed area for at least 5 weeks. The area showing the heaviest grazing use was the relatively flat "irrigated hayland" portion of the reclaimed area, with even the noxious weed species grazed. It seems questionable whether such heavy growing season grazing during the second year after seeding is "promoting the postmining land use", particularly with respect to the irrigated hayland acreage. The application narrative should be expanded to discuss how grazing will be managed to promote the postmining land use, and how the vegetation will be assessed in determining when grazing pressure can be tolerated. 3. Rule 4.15.9 requires that, "for areas to be used as cropland, success of revegetation shall be determined on the basis of crop production from the mined area as compared to approved reference areas or other approved standard(s)." On this subject, all I could find in the application was a statement indicating that, for the cropland area, "productivity will be compared to adjacent cropped areas." Considerable elaboration is necessary with respect to identification of the reference field, description of the comparison methodology (e.g. use of a specified sampling technique or a total harvest method), and discussion of statistical testing if comparison will be based on sampling. The operator should refer to the Division's April, 1995, GUIDELINE REGARDING SELECTED COAL MINE BOND RELEASE ISSUES, and the 1988, GUIDELINES FOR COMPLIANCE WITH LAND USE AND VEGETATION REQUIREMENTS FOR COAL MINING. 4. For the non-cropland portion of the reclaimed area, woody plant density and species diversity standards are clearly set forth in stipulations to the findings document, and both the findings