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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. 6) 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)." The only discussion found on this topic 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. Please 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. 7) 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 document and the permit application indicate that cover and production success determination will be based on reference area comparison. A reference area has been established in a big sagebrush vegetation type near the minesite, and the application on page 3-64 indicates that NCIG "will utilize cover and production data obtained from the reference area during bond release as standards of success." Unless information can be provided to justify an alternative approach, the application narrative should be amended to clarify that the success comparison will be based on herbaceous production and total vegetation cover. 8) Section 4.4.4 of the application includes a discussion of vegetation sampling methods and statistical comparisons to be used in demonstrations of revegetation success. The narrative indicates that cover sampling would be by line intercept, production sampling would utilize double sampling of one square meter quadrats, and woody plant density would also be sampled using one square meter plots. Line intercept is an acceptable approach, but it is very time consuming, and from that perspective, less efficient than the point intercept technique more commonly employed in revegetation sampling. Use of double sampling for