2015-10-13_REVISION - C1981014 (18)

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is less than 90 percent of the standard, an operator may employ hypothesis testing to demonstrate that the difference is not statistically significant. Historical Data. There has been considerable historic data collected from the Southfield Mine area. While it is recognized that these data cannot be used to document the successfulness of the current reclamation efforts at either the Southfield Mine or Southfield Loadout Areas, these data are useful in that they document baseline conditions and trends for the reclamation areas being evaluated in this bond release evaluation. The initial baseline vegetation studies started in 1980, when Keenan, Inc., issued a report "Vegetation Inventory - Reference Area Cover and Density Analysis," and has been referenced in every permit renewal since. Included in Keenan, Inc's, report were detailed data pertaining to the Refuse Site Reference Area, Mine Portal Reference Area, and the Railroad Coal Loadout Reference Area. Plant over was collected using the plant basal cover sampling methodology and woody plant density data were actual tree and shrub counts. Forage production data were not collected. In the summer of 2010, IME collected interim reclamation monitoring on the identical three reclaimed areas being evaluated in this analysis at the Southfield Mine and Loadout area. The parameters of plant cover, forage production and woody plant densities were sampled. These data were included in a report entitled "Revegetation Monitoring Report for Reclaimed Areas Sampled in 2010 at the Southfield Mine. " Plant cover data was collected using the point intercept method and forage production measurements were taken by plant species including annuals and shrubs. Woody plant density was sampled using 100 square meter belt transects. In the fall of 2008, IME performed baseline sampling on the proposed Portal Reference Area, which was subsequently submitted as TR -39. Plant cover data was collected using the point intercept method and forage production measurements were taken for perennial herbaceous species. Woody plant density was sampled using 100 square meter belt transects. Baseline vegetation monitoring was performed by IME in 2007 on the Southfield Loadout site, in connection with the permitting efforts for the Northfield Mine, located to the west of Florence on Chandler Creek. Initially, it was planned to use the original Dorchester Coal, Loadout Reference area during this sampling effort, but when the site was examined, it was discovered that the canal company had placed approximately eight to ten feet of fill over the entire area, completely destroying the possibility of this area being used as the Loadout Reference Area. Thus, a new location of undisturbed ground immediately adjacent to the Loadout Reclamation was sampled. The parameters of plant cover, forage production and woody plant densities were sampled. These data were collected in connection with the Northfield Mine Permit Application, but were never submitted to the CDRMS. Plant cover data were collected using the point intercept method and forage production measurements were taken only for perennial herbaceous plant species. Interim reclamation monitoring was performed by IME in 2006 on three reclaimed areas corresponding to the western third of the Refuse Pile reclaimed in 2003 which was combined with the Vento Portal Reclamation Area reclaimed in 2003 and the Corley Reclamation Area reseeded for a second time in 2004. The Loadout Reclamation was also sampled in this monitoring effort.