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Mowry - TR 5 Somerset - 4 - November 5, 1987 occur. Therefore, I do not believe weedy species should be controlled unless they are "obnoxious species" as defined by the Department of Agriculture or the weedy species remain a dominant component of the community after the third year following seeding. Also, if control is to be done it should be accomplished by using selective herbicide rather than mowing since it is usually less destructive. C. Concern No. 8 of September 22, 1987 Letter The proposed monitoring plan closely follows the method used for the baseline inventory. As such, it is an acceptable plan. However, some concerns or clarification are identified below. The monitoring plan is to ". begin the third year after initial planting" and ". will be done as necessary but not to exceed two years." I am uncertain what the second clause addresses; however, I looked at same of the approved monitoring plans for other mines. The Division has routinely approved monitoring for year 2, 4 and 7 after initial seeding. (The last two years of the liability period (year 9 and 10) are not considered monitoring.) Such monitoring programs have been instrumental in identifying problem areas, identifying trends, and providing an excellent picture of the potential for revegetation success. I would recommend monitoring be done for years 2, 4 and 7 at this mine. 2. I am uncertain what point the operator is trying to make on page 1 under "Revegetated Area Sampling Design." Whatever the attempted point is, it should be noted that for reclaimed areas sample adequacy will need to De obtained (which should not be as difficult as for baseline areas since cover should be more uniform on reclaimed areas thus reducing the number of required samples). 3. The operator is proposing to use the same sample adequacy formula as used in the baseline survey. According to Mike Savage, this formula was originally used by Wyoming for surveying both affected and reference areas. The Division's proposed guidelines (currently in draft form) are similar except we do not have a multiplier of 2 in the numerator. According to Mike, this gives you a number of required samples double what is really needed. Therefore, the operator could modify the sample adequacy formula by deleting the 2 in the numerator, if they so desire. 4. To insure there is no confusion, woody plant density should be determined following the countable criteria as set forth in Rule 4.15.8(7).