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<br /> <br />J.A. Stover and Associates - 2 - January 17, 1991 <br />composed of more than one identifiable community. Also, the chained area <br />inside the permit is probably a different commun ity. This would need to be <br />documented by sampling results also. <br />The second set of comments here relate to additional requirements of Rule <br />4.15.7 (Determining Revegetation Success). The major purpose for fathering <br />baseline vegetation data is after all, to have a means of determining <br />vegetation success. Lillylands will basically have two options for setting <br />revegetation success standards for cover and productivity. One is to <br />establish reference areas and the second is to set standards based on <br />technical documents which would need the approval of the Division and the <br />Director of OSM. Diversity and woody plant density standards may be based on <br />pre-mine data. <br />If reference areas are to be established, it will be necessary to demonstrate <br />that the selected areas are in fact equivalent to the areas to be disturbed, <br />in compliance with Rule 4.15.7(3). This topic is also covered in the <br />guideline mentioned above. <br />What this means for Lillylands is essentially that baseline vegetation data <br />from the proposed disturbed area needs to be collected and reported in a <br />manner such that the Division can determine if sample data is accurate enough <br />to meet the requirements outlined in the vegetation guidelines. If reference <br />areas are to be established, the permit application must demonstrate <br />statistically that proposed reference areas are equivalent to proposed <br />disturbed areas. As the information submitted indicates that the peak growth <br />season at the site is from early April to late June, it would be most <br />appropriate to conduct vegetation analysis in late June or early July. <br />Hopefully, this gives you a better idea of what is required in the way of <br />baseline vegetation data. If you have any further questions, feel free to <br />contact the Division. <br />Sincerely, <br />J -~ <br />~ ~ <br />~~.2~ ,/' ./emu <br />Larry P. Routten <br />Reclamation Specialist <br />LPR/yjb <br />CC: Mike Savage <br />Tony Wal dron ~. <br />2861E <br />