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_21_ The Division requested a qualitative description of the saltflat vegetation type found at the Kerr site (October 9, 1980, letter to Kerr). Kerr provided this information via a letter to MLRD on November 6, 1980. The Division expressed concern over maintenance of riparian vegetation found in the draws on the Kerr site and requested Kerr to develop a separate seed mix for these small areas (November 6, 1980). Kerr responded by stating that seeds for these species were not available, but transplants of the seven main riparian species would be undertaken to reestablish the community type in the draws (December 4, 1980). MLRD requested that the management practices such as utilizing pesticides or herbicides, or controlled burning be approved by the Division prior to implementation. Kerr agreed to this request in their November 21, 1980, letter to OSM and correspondence to the Division office (December 4, 1980). Concern over statistical formula was expressed by MLRD on October 9, 1980, and November 6, 1980, letters to Kerr. Kerr responded adequately in their November 6, 1980, and December 4, 1980 letters to MLRD. An ongoing Division concern has been the revegetation success at the Kerr Tipple. At a meeting between MLRD, OSM and Kerr on November 10, 1980, the issue was discussed and in their December 4, 1980, submittal to MLR, Kerr made an acceptable proposal for revegetation success. Data from the proposed reference area will be submitted no later than September 30, 1981, for Division analysis and approval. The sample adequacy of certain parameters in given vegetation types has been of concern to MLRD, and was questioned in the Division's November 6, 1980, December 5, 1980, and December 23, 1980, letters to Kerr and OSM's apparent completeness review. Kerr has responded satisfactorily to all concerns. The Division had a concern over failure of stubble mulch and the criteria for success (MLRD's November 6, 1980, December 5, 1980, and December 23, 1980) letters. Kerr responded in a December 23, 1980, letter and clarified their response in a meeting held December 31, 1980, between Kerr and MLRD. The plan submitted by Kerr is acceptable. The issue of shrub density and shrub reestablishment has been a concern evoking much discussion. MLRD requested that Kerr address this subject (November 6, 1980). Kerr provided a discussion of their aims and asked MLRD for a variance from the requirements of 4.15.8(7) to reestablish 2,000 stems/acre shrub density. Due to insufficient supporting evidence, the Division was unable to approve the requested variance. The following stipulation was therefore necessary: With respect to shrub density the permittee provided additional supporting evidence which allowed the Division to accept 2000 stems/acre as the success standard.