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V <br />C1'l{1 Q9R lr�.._ar-n T1C. <br />r Mx».w Cew.x-.n vu. xa�ar,• <br />areal measurements yields a minimum area that can be sampled without violation of statistical theory. <br />Effectively, this mandate is that sampling units cannot criss-cross or otherwise overlap which would then <br />violate the assumption of independence. Given that the sampling protocols utilized at Snowcap for <br />woody plant density involve 2m X 50m belts, a minimum sampling unit would have to be somewhere in <br />the one to two acre size to facilitate sufficient samples without overlap. <br />Finally, the smaller the target unit for sampling, the greater the chance for the biologist(s) collecting <br />those samples to influence them by trampling the very vegetation that is to be measured. Typically, <br />vegetation sampling protocol requires the samplers to position themselves to the side to avoid influencing <br />that which they measure. When small areas are sampled, the probability of influencing another sample <br />increases dramatically. <br />In this regard, adequate sampling of a small re -disturbed and reclaimed area could and should be limited <br />to the collection of ground cover data using the point -intercept technique. This variable and technique is <br />the one typically utilized for Phase 11 analyses to aid the determination of adequate ground cover to <br />control erosion. However, because of the issues noted above, the absolute minimum unit for application <br />of this protocol should be limited to one acre or larger, and only ground cover sampling using point - <br />intercept would be appropriate for adequacy testing. In this regard, Cedar Creek would recommend that <br />protocols applied for Phase II testing as opposed to Phase III bond release evaluations (cover, <br />production, density, and diversity) be applied to small areas of re -disturbance late in the reclamation <br />phase of a mining operation. <br />In order for a small reclaimed area (<1.0 acres) to meet revegetation success, vegetative cover <br />(determined visually) must be adequate to control erosion and similar to the reclaimed area or <br />surrounding undisturbed area. A small reclaimed area will not be subject to the extended liability period <br />of 3.02.3(2) or the bond release criteria of 3.03.1(2). <br />TR -69 <br />A14-16-2 <br />12/16 <br />