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4 <br />The historic shrub density data were collected using the point -center quarter plotless sampling method, <br />which is no longer a recommended shrub density sampling methodology found in the CDRMS <br />Vegetation Guideline. This does not invalidate the previously collected data, as this sampling <br />methodology was widely used and accepted by the CDRMS in the 1970s and 1980s. Also, this <br />methodology still appears in a number of studies in the scientific literature, but CDRMS dropped this <br />sampling technique because it is slightly more complex to use and interpret than are the belt -transects or <br />quadrat shrub density sampling techniques found in the CDRMS Vegetation Guideline. Examination of <br />the existing Trapper Mine Permit reveals the shrub data are summarized only by total numbers and are <br />not totaled by species in Permit Table 2.3-9 even though these same data are reported by species in <br />Table 2.3-15. <br />Details on the current field sampling and data analysis methods follow <br />2.2.3.1 Plant Cover <br />In this evaluation, plant cover was evaluated by sampling ten randomly chosen intervals along the <br />outstretched 50 -meter transect tape. At each designated sample position, an inclined, metal ten -point <br />frame one meter in height and width was positioned perpendicular to the tape. Even numbered positions <br />were sampled on the right-hand side of the tape and odd numbered positions were sampled on the left- <br />hand side of the tape in order to further randomize the cover transect samples. <br />Then a sharpened metal rod was dropped through each of ten slots separated by 10 centimeters. Each <br />observation was recorded according to the specific plant species the sharpened rod intersected first as it <br />was dropped. If no plant cover was encountered, then the observation was recorded as to the presence <br />of plant litter, rock, bare ground, lichens or cryptograms intersected at the ground surface. Dead plant <br />material produced in the 2014 growing season that was still attached to a living plant was recorded as <br />part of that living plant, and dead plant material that had fallen to the ground was recorded as litter. The <br />100 data points collected along each transect were summed for the entire transect for further statistical <br />analysis. Absolute and relative plant cover, species diversity, and plant life forms were determined based <br />upon the observations collected in the sampled plant cover. For each vegetation type sampled, a <br />minimum of 15 cover transects were sampled before sample adequacy was calculated. If the calculated <br />value required additional transects, these were chosen from a pool of additional sites and sampled using <br />the same methodology. <br />2.2.3.2 Production <br />Three randomly located circular plots measuring one-quarter square meter were clipped along each of <br />the vegetation transects. The production plots were clipped by life form for perennial grasses, perennial <br />forbs, annual grasses, annual and biennial forbs, and noxious weeds. The instructions found in <br />Rule 4.15.11(1)(b) require that only "current annual growth of herbaceous, non -woody, species" are <br />clipped for production; however, the historic production sampling at Trapper Mine used all current annual <br />herbaceous growth in the samples and were not summarized by plant life form. This study replicated <br />these same historic methods to summarize production information. Thus, all annuals, biennials and <br />noxious weeds were also clipped so that the 2014 data could be compared with the previously collected <br />baseline information. However, the 2014 production data also were summarized by plant life forms so <br />these data can be compared to the current standards. <br />As directed by the CDRMS regulations at Rule 1.04 (55) and on page 9 of the CDRMS Vegetation <br />Guideline, half -shrubs were clipped and lumped with perennial forbs in the production sampling. The <br />production samples were usually taken along the same transect used for cover and shrub density <br />sampling. The three clip plots were summed as a single transect datum for later statistical analyses. For <br />each vegetation type, a minimum of 30 production transects were used for initial sample adequacy <br />