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<br />2. Reference to achievement of 80% statistical confidence levels on <br />revised pages 780-137 and 780-137(6) nest be deleted. Recent rule <br />changes specify 90% confidence levels regardless of vegetation or <br />land use type. <br />On page 780-137(c), it is stated that weighted cover and <br />production averages will be compared to cover and production <br />on the pastureland reference area. Presumably, the weighting <br />would be based on acreage of individual parcels within the block. <br />However, since the reclamation blocks in the pastureland type will <br />be compared solely to the pastureland reference area, a direct <br />comparison pursuant to Rule 4.15.7(4)(a) is actually being <br />proposed, rather than the weighted average technique of Rule <br />4.15.7(4)(b). This should be clarified and a more detailed <br />description of what is meant by the weighted comparison in the <br />context of paragraph number 1 of revised page 730-137(c) should be <br />provided. As long as samples are randomly distributed throughout <br />the various parcels in a "block," and sample adequacy is achieved <br />for the block as a whole, acreage based weighting would not be <br />necessa ry . <br />4. In the cover letter, CYCC refers to a proposed change in the <br />species diversity standard for pastureland, but the change is not <br />specifically addressed in the text of the application. The <br />standard as set forth at the bottom of page 780-137{a) would need <br />to be revised. The following wording is recommended: <br />"relative production of alfalfa shall not exceed 75%, <br />perennial grass shall provide at least 25A relative <br />production, and no single species shall exceed 754 <br />relative cover." <br />If three years old revegetation monitoring were to be terminated in <br />1990, the monitoring change on page 780-133 would be acceptable. <br />However, since this is not the case, I would recommend that the <br />following sentence be inserted after the 3rd sentence of the 2nd <br />paragraph of revised page 780-138. <br />"In future years, production will be sampled in addition <br />to cover and woody plant density on all 3 year old reclaimed <br />sites, and the need for further monitoring on soil testing <br />will be based on production as well as cover." <br />Please contact us with any questions. <br />Sincerely, <br />/' <br />~~L~ <br />David A. Berr~~ <br />Reclamation Specialist <br />DAD/eke/1231F <br />cc: James C. Stevens, hLRD <br />