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21. In various sections of the application it is indicated that the cover standard for "post <br />law" reclaimed areas would be based on herbaceous cover levels as measured in <br />designated reference areas, and Exhibit 14, "Supplemental Vegetation Information <br />Report" is referenced. In that report, 1981 sampling data for herbaceous production, <br />total cover, and woody plant density for three sagebrush stands occupying different <br />aspects is presented. Total vegetation cover was estimated by point intercept <br />sampling, and the sample means for the three stands ranged fi-om 34.1% to 39.6%. <br />Given the rather modest cover levels in the reference stands, it is recommended that <br />the application be revised to specify that the cover standard be based on total cover <br />rather than herbaceous cover. Herbaceous cover alone, at th.e levels represented, <br />would likely result in excessive erosion. <br />22. Species diversity standards set forth in the application are based on the Shannon- <br />Wienerdiversity index approach originally recommended in "A Survey of Techniques <br />for Measurement of Herbaceous and Shrub Cover, Production, and Diversity on Coal <br />Lands in the West" (Bonham, et.al. 1980), and "The Concept of Species Diversity in <br />the Evaluation of Revegetation Success" (Larson, 1980) and detailed in the Harner <br />report in Exhibit 14. <br />The standards as stated in the text of the application however, do not conform to the <br />approach recommended in the referenced papers, or to the recommendations in <br />Exhibit 14. For example, the diversity standard proposed for the Williams Fork Strip <br />Pit states that "diversity will be successful when H totalled from four species from the <br />revegetated area contribute 48% to the calculated total H from the revegetated <br />area." If there were four principle species in the premine area which contributed <br />48% to the total H, and each individually contributed between 7% and 15% to H, <br />the standard based on the Bonham and Larson approach would be as follows: <br />Diversity will be successful when a minimum of four principle species <br />of the same life form and seasonality as the principle species identified <br />in the premine data each contribute between 7% and 15% to the <br />diversity index of the reclaimed area. <br />The diversity standards in the application should be revised to be consistent with use <br />of the Shannon-Wiener Index as discussed above, or alternatively, the diversity index <br />could be replaced with a more straight-forward species composition approach as <br />recommended in the Division's Vegetation aad Land Use Guidelines. In either case, <br />in the interest of practicality, it is suggested that the number of separate diversity <br />standards applicable to different areas be minimized (it is probably not necessary to <br />have a different standard for each aspect of the refuse pile, another standard for the <br />Williams Fork Strip Pit, and yet another standard for other adjacent areas that are <br />reclaimed with the same seedmix. <br />