REV92704 - Laserfiche WebLink

Home Browse Search

3. Hypothesis testing was not required in order to demonstrate successful cover establishment for any of the parcels sampled, because in each case, the reclaimed area parcel sample mean exceeded the reference area sample mean, as shown in the summary table on page A-2. The mean cover data as presented in Table 2 does not reflect adjustments to account for annual/biennial species and noxious weeds as specified in the guideline. Although it would appear that the cover standard will still be achieved for each parcel when this adjustment is made, the table should be amended to include the adjusted cover values, and the summary descriptions in the Vegetation Results section should also be amended to reflect this adjustment. 4. In the Vegetation Discussion section on page A-6, it is stated that average vegetation cover for the dryland and AVF areas was 13.7$ and 72.6$, respectively. These figures appear to be numeric averages, rather than acreage weighted averages. Use of the numeric average would be inappropriate for comparison against the reference area standard, but in this case it is of no consequence because each parcel exceeds the reference area standard individually. 5. Based on species composition cover data, the Barren Ridge, Revision 1, and 1990 AVF parcels appear to clearly meet the regulatory criteria ("vegetation which supports the approved postmining land use"), and the guideline elaboration ("all species required to meet final diversity and seasonality requirements should be represented in the sampling data"). East Pit reclaimed parcels do not appear to meet these criteria, due to lack of warm season grasses (West Slope '84, '91, Topsoil Stockpile, Top Slope, North Flat), lack of approved perennial forbs (West Slope '91, Topsoil Stockpile, Top Slope), and noxious weed infestation (Topsoil Stockpile, South Slope, East Slope). The 1991 AVF area would appear to be quite weedy, with a significant component of field bindweed. Based on these reasons, my initial recommendation would be that Phase 2 bond release should not be approved for the East Pit reclaimed area, or the 1991 AVF area. 6. The AVF quadrat sampling production data referenced on page A- 6 does not appear to have been included in the application. This data should be provided. 7. Some explanation should be provided for the large discrepancy between AVF reference area production based on hay harvest versus quadrat sampling. 8. In the data sets, common sunflower is incorrectly listed as a perennial forb rather than annual, dandelion is listed as an annual rather than a perennial, and yellow and white sweetclover are listed as perennial rather than biennial.