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Ralph F. Cox <br />Joseph A. Wagda <br />Barry J. Galt <br />Dennis E. Logue <br />3. Abraxas Petroleum Corporation <br />In AVS Robert W. Carrington is still listed as a Director, but he is not <br />listed on page 9A or 9$, dated 6/28/04. If he is still a Director please <br />revise the permit page to list him as such, otherwise please submit <br />documentation showing an End Date so that AVS maybe updated. <br />Rule 4.15.7(21- Determinine Reve2etation Success <br />4. Various sections of the permit application, as well as the RN-03 and SL- <br />02 Findings document that Eastside Mine disturbed areas qualified as <br />"previously mined azeas" pursuant to Rule 4.15.10(1). As such, the only <br />vegetation success criterion applicable is "ground cover of living plants". <br />A success standazd of 35% cover is specified in the approved permit and <br />referenced in the RN-03 Findings document. <br />Rule 2.05.4(2)(e)(vi) requires that the revegetation plan include a <br />description of measures proposed to be used to determine the success of <br />revegetation. Rule 4.15.7(2) requires that the description include <br />measurement methods to be used and statistical tests to be performed. <br />The reclamation plan section of the permit application specifies the 35% <br />cover success standazd, and indicates that "the line intercept (point) <br />method with random 100 foot transects" would be employed for success <br />evaluation. The method was slightly modified, and description was <br />greatly expanded in the 2000 Quantitative Vegetation Study, which was <br />accepted by the Division as a part of the SL-02 Phase II bond release <br />application (approved in 2001). <br />The Division requests that the very brief reference to sampling method on <br />page 91 and 92 of the permit application be amended to more fully <br />describe the sampling approach and specific methods to be employed, <br />including statistical sample adequacy and testing methods. <br />Please amend the discussion of revegetation success measurement <br />methods on pages 91 and 92 of the application to more fully address <br />proposed cover sampling technique, statistical sample adequacy and <br />testing formulas and confidence levels, and data presentation and <br />