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document and the permit application indicate that cover and production success determination will be based on reference area comparison. Evidently, a reference area has been established in a big sagebrush vegetation type near the minesite, and the application on page 3-64 indicates that NCEC "will utilize cover and production data obtained from the reference area during bond release as standards of success." Unless information can be provided to justify an alternative approach, the application narrative should be amended to clarify that the success comparison will be based on herbaceous production and total vegetation cover. 5. Section 4.4.4 of the application includes a discussion of vegetation sampling methods and statistical comparisons to be used in demonstrations of revegetation success. The narrative indicates that cover sampling would be by line intercept, production sampling would utilize double sampling of 1 square meter quadrats, and woody plant density would also be sampled using 1 square meter plots. Line intercept is an acceptable approach, but it is very time consuming, and from that perspective less efficient than the point intercept technique more commonly employed in revegetation sampling. Use of double sampling for production data is not acceptable, all production samples should be clipped, dried and weighed. Woody plant density sample adequacy would not be attainable using i square meter quadrats; belt transects at least 2 meters wide and 50 to 100 meters in length would be more appropriate. The application text regarding sampling techniques for success comparison should be appropriately amended. The text states that statistically adequate samples will be collected for all three parameters, and will be compared "using the formula in Section 3.6.2.3.4 of this application." I could not find this section in the application on file at the courthouse. Page 3-64 of the application states that "statistically adequate samples will be obtained from the reference area and the reclaimed areas and compared by a statistical method acceptable to the state during bond release." Some clarification is necessary. Unless a more specific proposal is desired by the operator, it is recommended that the following commitment be included in the appropriate section of the reclamation plan: For demonstration of revegetation success, the parameters of vegetation cover, herbaceous production, and woody plant density will be sampled to statistical adequacy and compared to the appropriate reference area sample mean (cover and production) and numerical standard (woody plant density). Diversity comparisons will be made based on relative cover values obtained from the statistically adequate sampling. Statistical adequacy of reclaimed area and reference area sampling will be demonstrated using formulas recommended in the Division's current bond release guideline. Statistical tests of success will also follow the procedures recommended in the bond release guideline.