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revegetation reports is in general thorough and well presented. Data presented for the <br />`91-93 seeded areas indicate that a relatively diverse vegetation cover is becoming <br />established, with woody plant densities in excess of 1000 stems per acre. However, there <br />appeaz to be a couple discrepancies between the monitoring plan specified in the permit <br />application, and the monitoring reports as submitted. <br />First, the application states on P. 35, Tab 22, that "periodic monitoring of a given area of <br />reclamation (id'd by year of initial seeding) will be conducted in years 2, 4, and 7." 1996 <br />would have been the second year for the '94 seeding, and 1997 would have been the <br />second year for the `95 seeding, however no monitoring data was included in the `96 or <br />`97 reports for the `94 or `95 seeding areas. Some explanation will need to be provided. <br />Second, the application narrative also indicates [hat vegetation production sampling <br />would be conducted as a part of the monitoring program, and that production data would <br />be included in the revegetation monitoring reports, but no production data was included <br />the the 1995 or 1996 revegetation reports. Page 2 of the 1997 revegetation report states <br />that no production sampling was undertaken in 1997, but page 6 of the same report states <br />that production sampling was conducted, and in fact production data is reported in Table <br />2 of the report. An explanation for why production was apparently not sampled in 1995 <br />or 1996 should be provided, and erroneous sections of the 1997 report should be <br />corrected. <br />This is getting pretty picky, but there is some muddled text on page 45, Tab 22, which <br />was apparently revised via TR-26, and which should probably be clarified. The fourth <br />sentence of the third paragraph states, "In the mesic drainage-wetter phase sites along Dry <br />Creek, at least 150 tree species per acre will be included in the 2000 stem density <br />standard." That's a lot of tree species! I assume what the operator means is that at least <br />150 stems per acre will be trees. <br />4. Soil replacement thickness data has been reported in each of the annual reports, as <br />required. 1995 and 1996 reports indicated average replacement thickness of 16", which is <br />the regired topsoil replacement thickness. 1997 average replacement thickness was 12", <br />apparently based on DMG sampling. 1 don't know whether we decided that this amount <br />of variation was acceptable, or whether we raised it as a concern in the inspection report. <br />You should check with Erica Crosby, and see what her thoughts were. Some <br />acknowledgement and explanation regarding the apparent lower replacement thickness <br />for the 1997 topsoiled area should probably be included in the ARR. <br />cc: David Berry <br />miscmine\2w98 mtrm. mem <br />