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r <br />29. The text and tables were amended as requested. Item Resolved. <br />30. Text was properly amended to commit to representatively sampling woody plant <br />density within designated shrub establishment areas. Regarding documentation of <br />presence/absence of shrub areas within a given year's revegetation parcels...point <br />taken! Item Resolved. <br />31. Narrative reference to the Division's April 1995 guidelines document was <br />amended as requested. Item Resolved. <br />32. SCC's response to this item on page 10 of the cover letter is not consistent with <br />narrative on amended pages 39 through 41 of Tab 22. The cover letter response <br />states that "SCC will only sample for cover in the wider sampling universe. The <br />shrub establishment areas will also be included in this wider universe". However, <br />the amended text pages describe a plan for sampling cover separately within <br />"Shrub Grassland" areas as opposed to "Shrub and Tree Concentration Sites". <br />The plan also indicates that different cover success standards would be applied to <br />each type. Please address this contradiction between the cover letter and the <br />amended text, and revise the text as appropriate (if such text amendment was <br />intended). <br />33. Requested clarification regarding cover sampling technique for the Mesic <br />Drainage type was provided. Item Resolved. <br />34. SCC did not provide a definitive response or documentation to demonstrate that <br />adequate baseline data has been collected to establish a "historic record" standard <br />based on pre-mine production data for the haul road con;.:o_. SCC indicates in <br />the cover letter that they "will conduct an evaluation of [the previously collected] <br />data and determine if more data will need to be collected over the next few years. <br />If the collection of data is significantly different from the existing plan SCC will <br />consult with the Division before such sampling is conducted." <br />We note that the concern initially identified by the Division with respect to the <br />pre-mine data based production standard, would also apply to the pre-mine data <br />based cover standard. <br />Please include a specific commitment within the pertinent permit text, stating <br />that a demonstration of compliance with the provisions of Rule <br />4.15.7(2)(d)(v) will be made, or a complete revision application describing <br />future sampling to be conducted for the purpose of establishing the historic <br />record standard for cover and herbaceous production will be submitted to <br />the Division, no later than December 31, 2006. <br />35. SCC referred to their responses to specified preceding items, and we will do <br />likewise. Item Resolved. <br />