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<br /> <br />c) Please refer to page 20 of this guidance document for the formula to use for determining sample <br />adequacy when the reclaimed area data are less than the reference azea standard. <br />2. The Division considers that half-shrubs contribute to the reclaimed area diversity as a <br />perennial forb. Winterfat can be counted toward the perennial forb species diversity <br />requirement. Inclusion of Winterfat cover data as contributing to the perennial forb diversity <br />achieves the requirement for establishment of two perennial fortis >3% but <40% relative <br />cover. <br />3. June sampling did not adequately identify warm season grasses that were identified during <br />the September sampling. September cover sampling results do not differ drastically in the <br />life form compositions supporting Kaiser's claim that during June Warm season grasses were <br />misidentified as cool reason grasses. The Division suggests that sampling later in the season, <br />perhaps early July may aid in grass species identification. <br />4. Kaiser performed glazing several yeazs ago. The bond release application should include a <br />description of when the grating conducted including, duration, and number of animals, and location <br />grazed. <br />5. Sample adequacy was not achieved for production data. The Division observer who was present <br />during the June sampling event noted that only one production plot was collected along each cover <br />transect. The Division suggests that more than one production quadrat be collected along each <br />transect in order to achieve sample adequacy. <br />6. The report indicates that Figure A-4 was included. This figure was not included in the <br />package submitted to the Division. <br />I have not analyzed the non-parametric productivity data using the Statgraphics program. <br />However I conferred with Larry Routten regarding comparison of the Median on the reclaimed <br />area and the Mean from the reference area. He stated that this is valid for comparison. The non- <br />parametric analysis that Kaiser (Greystone) perfotmed on the productivity data is agreement with <br />the non-parametric analysis that the Division recommended the same consultant use for another <br />mine site. <br />If 1999 data is consistent with the 1998 data, cover, diversity and life form success standards <br />should all be able to be achieved by the operator. Productivity data indicates that Kaiser should <br />be able to show successful vegetative production on the reclaimed area. <br />If you have any questions, please contact Janet Binns directly to discuss with her. <br />Since ly G~ ` n <br />K ~t A. Gorham //~y4/' <br />Environmental Protection Specialist <br />