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- 9 - <br />data were to indicate that plant cover and production were similar to <br />areas that are seeded in a normal fashion, then the Division may <br />entertain a proposal to trying this method on other mine areas. <br />Vegetation - Rules 2.04.10, 2.05.4(2)(e) and 4.15 <br />40. The revised permit application contains a rewritten "Section 2.04.10 - <br />Vegetation Information." The Division requires that Kerr Coal clarify <br />the following issues regarding this part of the application: <br />a. A comparison of revised charts delineating cover and production for <br />vegetation types with their old counterparts revealed consistent <br />differences. Please explain why the present charts, even for <br />vegetation communities which have not been changed, do not exactly <br />correlate. <br />b. Kerr Coal has deleted the charts which describe the vegetation <br />component of reference areas. Please insert this information into <br />the permit application. <br />c. Please discuss the decisions to combine four of the originally <br />delineated major vegetation communities into two. Please include a <br />discussion which addresses in greater detail how those proposed <br />changes will affect the presently approved re vegetation plan. <br />Include a comparison of communities to be combined with respect to <br />important regulatory parameters such as herbaceous productivity and <br />total vegetation cover. Finally, Kerr Coal should describe how <br />cover and productivity values were calculated for new combined <br />vegetation communities. <br />41. Page 816-156a of the presently approved permit application states: "Other <br />than the acreages used to weight the post-mine reference area data, <br />pre-mine vegetation work will be used to establish valid reference areas <br />only and not in the determination of re vegetation success." Paae 4.15-13 <br />of the proposed permit application concurs that only reference areas and <br />previously agreed upon standards will be used to determine reveaetation <br />success. In light of these two page references, Kerr Coal needs to <br />explain or adjust the following statement which appears on pane 2.05.4-43: <br />"For the Kerr mine area, the reference area standard will be <br />calculated based on data collected from the three (3) reference <br />areas during years nine and ten of the liability period combined <br />with baseline data for the Salt Flat vegetation type." <br />A similar statement also exists on page 2.04.10-21. <br />42. Page 4.15-18 states that in evaluating re vegetation success, a two tailed <br />t-test will be used. Furthermore, the reveaetation will be considered <br />successful if cover and production mean of the reclaimed area is greater <br />than or equal to the calculated 80~ confidence level for the reference <br />area value ". Page 17 of the Division's Land Use and Vegetation <br />Guidelines and Rule 4.15.7(2)(c) require that tests mus pro vi a results <br />va-Ti"d at the 90`X confidence level, using one-sided tests with a 0.10 <br />alpha error probability. Kerr should adjust the text to reflect this <br />requirement. <br />