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Memo - Cathy Begej - 4 - January 24, 1990 <br />Commitments regarding fencing and grazing plans which address <br />Rules 4.15.7(3), 4.15.1(3), and 4.15.5 were found in the following <br />locations: <br />Addendum 1 <br />Addendum 2 <br />Addendum 5 <br />Addendum 6 <br />Communication, dated 2/2/82 from David Stout to Steve Manger of OSM. <br />These commitments should be directly incorporated into the main body of <br />the permit application. <br />For your information: Their most important commitment is found in <br />Addendum 6: "Prior to initiating grazing on the reclaimed land Wyoming Fuel <br />Company will submit a grazing plan to the regulatory authorities. During the <br />9th and 10th years of the liability period the reference areas and the <br />reclaimed land will be managed the same. Grazing capacities of the reclaimed <br />land will be based on vegetative analysis obtained during the vegetation <br />monitoring program. Parameters such as species composition, cover, <br />productivity and plant rigor will be utilized to determine stocking rates." <br />As is, the commitment, while very general, is acceptable. There are two ways <br />you could make it more specific if you wanted to. You could ask them to <br />revise the commitment to require them to submit the plan 3 or 6 months in <br />advance of its implementation to allow review time. You could also ask them <br />to submit a plan now as 1990 is year 9 on the 1981 revegetation area. <br />10. Rye Grass Competition Study <br />Addendums 6 and 8a include the commitments regarding a rye grass <br />competition study. Addendum 8a states that WFC would submit the results <br />of this study by January 30, 1983. A search of our files did not result <br />in location of a document of this nature. Please submit a copy of the <br />results to the Division. <br />11. Statistical Evaluations <br />The regulations pertaining to levels of statistical certainty have been <br />revised. Rule 4.15.7(2)(c) notes that statistical tests "must provide <br />results valid at the 90 percent confidence level, using a one-sided test <br />with a 0.10 alpha error probability." Rule 4.15.8(7) states, <br />"Establishment of woody plants on the re vegetated area shall be <br />considered acceptable if the density or other applicable parameter is not <br />less than 90 percent of the approved reference area or standard with <br />90 percent statistical confidence." WFC should revise the permit <br />application to reflect current regulations. <br />