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w, <br />component of early successional annual fortis and grasses, including some cheatgrass. <br />However, seeded perennials and desirable volunteer species are well represented in the <br />stand, with intermediate wheatgrass, shadscale, fringed sage, Indian ricegrass, cicer <br />milkvetch, bluegrass, rubber rabbitbrush, and big sagebrush all having a significant <br />presence. The sediment pond area seeding appears to have been successful. <br />Document Review and Compliance Evaluation <br />Various sections of the permit application, as well as the RN-03 and SL-02 Findings <br />document that Eastside Mine disturbed areas qualified as "previously mined areas" pursuant <br />to Rule 4.15.10(1), As such, the only vegetation success criterion applicable is "ground <br />cover of living plants". A success standard of 35% cover is specified in the approved permit <br />and referenced in the RN-03 Findings document. <br />Rule 2.05.4(2)(e)(vi) requires that the revegetation plan include a description of measures <br />proposed to be used to determine the success of revegetation. Rule 4.14.7(2) requires that <br />the description include measurement methods to be used and statistical tests to be <br />performed. <br />The reclamation plan section of the permit application specifies the 35% cover success <br />standard, and indicates that "the line intercept (point) method with random 100 foot <br />transects" would be employed for success evaluation. The method was slightly modified, <br />and description was greatly expanded in the 2000 Quantitative Vegetation Study, which <br />was accepted by the Division as a part of the SL-02 Phase II bond release application <br />(approved in 2001). <br />My recommendation is that the very brief reference to sampling method on page 91 and 92 <br />of the permit application be amended to more fully describe the sampling approach and <br />specific methods to be employed, including statistical sample adequacy and testing <br />methods. I would suggest the following adequacy comment: <br />Please amend the discussion of revegetation success measurement methods on <br />pages 91 and 92 of the application to more fully address proposed cover sampling <br />technique, statistical sample adequacy and testing formulas and confidence levels, <br />and data presentation and summary approaches to be employed in association with <br />Phase III bond release. The amended plan should include sample design transect <br />location and methodology, sampling timeframe, and details of the point intercept <br />method to be employed (transect length, orientation, point spacing, instrument type, <br />etc.). The plan should specify a minimum of 15 sample observations Itransectsl and <br />include the sample adequacy formula and testing approaches to be employed to <br />demonstrate statistical validity at the 90% level of statistical confidence. <br />Alternatively, inclusion of a commitment within the application to conduct <br />vegetation cover sampling and statistical testing, and to provide data presentation <br />and summary for Phase III bond release consistent with the methods and format of <br />the 2000 Quantitative Vegetation Study, would be acceptable. <br />In either case, it will need to be clearly stated that the area subject to quantitative <br />sampling (the "sampling universe") will encompass the entire revegetated area, <br />including the reclaimed sediment control structures seeded in 2002. <br />C: Sandy Brown <br />