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14 <br />5,250 to 7,400 feet. Given the total absence of these habitat conditions on the PR -7 Mine Expansion <br />Area, it is essentially impossible that this plant would occur on this site. No individuals of this plant were <br />encountered on this site. <br />Alkaline Peooerwort <br />On the distribution maps, this species is reported to occur approximately 20 miles to the west of the <br />Trapper Mine. It is reported to occur in "openings of pinyorl*niper woodlands" and is often associated <br />with Gambel oak and Utah Serviceberry. It is reported to be "associated with Mancos shale"and Is "also <br />found on arroyo banks and greasewood flats." It often occurs at elevations ranging from 6,063 to <br />8,130 feet. Given the total absence of these habitat conditions on the PR -7 Mine Expansion Area, it is <br />extremely unlikely that this plant could occur on this site. No Individuals of this plant were encountered <br />on this site. <br />4.0 Conclusions <br />For the PR -7 Mine Expansion Area, intensive vegetation studies were conducted on three of the six <br />potential pre -disturbance vegetation types. As summarized in Table 2, Statistical Summary and Sample <br />Adequacy Calculations, a significant number of samples relative to total plant cover were collected on <br />each of these three pre -disturbance vegetation types to statistically describe the sites. Sample adequacy <br />was achieved for total plant cover sampling at the 90 percent confidence interval on the Mountain Shrub, <br />Big Sagebrush, and Grassland pre -disturbance vegetation types. Therefore, it can be concluded that <br />these sites were adequately sampled for the parameter of total plant cover. <br />With respect to forage production, it was determined that sample adequacy was achieved for forage <br />production on the sampling of the Mountain Shrub, Grassland and Big Sagebrush pre -disturbance <br />vegetation types to adequately describe these areas at the 90 percent statistical confidence level. <br />Therefore, it can be concluded that adequate production sampling was conducted on these areas. <br />With respect to shrub density, it was determined that sample adequacy was achieved for the Mountain <br />Shrub and Big Sagebrush pre -disturbance vegetation types to adequately describe these areas at the 90 <br />percent statistical confidence interval. On the Grassland vegetation type, sample adequacy was not <br />achieved with the 75 transects sampled, but since this value is the maximum sample size required for <br />shrub density found in Rule 4.15.11(3)(bKl), a sufficient number of samples was collected to describe <br />this plant community. These were described extensively in the results section. <br />In a mining operational sense, individual plant communities are never disturbed as discrete plant <br />communities, nor can reclamation ever be conducted based upon the exact alignment of individual pre - <br />disturbance plant community boundaries. Mining by its very nature often results in disturbance to multiple <br />plant communities at the same time. Reclamation likewise results in multiple plant communities being <br />reclaimed into a single reclamation block at the same time. Therefore, the discussion of the properties of <br />individual plant communities by themselves is essentially nothing more than an academic exercise. The <br />CDRMS recognized this problem many years ago in connection with the issues of bond release and <br />promulgated Rule 4.15.7.4(b) which allows for multiple plant communities to be combined Into a single <br />value via the concept of a "weighted averaging" technique. <br />This concept is further discussed in the Bond Release Guideline, wherein it is suggested the concept of <br />"weighted averaging" can be used for reclamation when various reclamation blocks could be lumped into <br />a composite reclamation value based upon the acreages of the various reclamation parcels. Given the <br />long acceptance of this practice, TMI believes that this concept can also be applied to the concepts of <br />