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While the new reference area is preferable to the old one, there <br />are questions about the appropriateness of comparing herbaceous <br />production in the reclaimed area (predominantly grass) and the <br />reference area (predominantly trees and shrubs). i discussed this <br />with Jim Stover last week and encouraged him to consider <br />establishing reclamation success standards based on technical <br />documents if and when the proposed regulations changes which are <br />being submitted to the OSM are approved. Standards designed for <br />the reclaimed site based on erosion control, site stabilization and <br />grazing requirements would be much more appropriate than the <br />reference area method. ' <br />When the regulations changes are approved, we might contact Stover <br />again. He seemed to agree that the technical standards would be <br />more meaningful. In the interim, there is at least, a reasonable <br />basis for comparisons of vegetative cover between the reclaimed <br />area and the reference area. <br />cc: Janet Binns <br />c:\wp51\1r122 <br />