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<br />rather than a species specific comparison. These concerns are addressed under <br />Section (2 ). At this time, the Division believes that a better way of <br />resolving this overall issue may be for WECC to pursue another way of <br />complying with species diversity requirements rather than to pursue resolution <br />of the items below. <br />Comparison Methods <br />The narrative does not address questions of how the similarity index <br />will be used in judging revegetation success. For example, in using a <br />diversity index, a number would be generated for both if•e reference and <br />the revegetated areas. These two numbers would then be statistically <br />compared. However, in using a similarity index, only one number will <br />be generated describing mathematically how similar the two areas are. <br />This number must then be compared to a predetermined standard. This <br />standard has not been addressed. WECC needs to expand the narrative <br />of Exhibit 4.6.1 .A to clarify comparison methods in compliance with <br />Rules 4.12.7 and 4.15.8(5). <br />2. Growth Form Categories <br />The third page of Exhibit 4.6.1 .A states, "the growth form categories <br />can be made more or less specific as determined by the regulatory agency <br />and the applicant." If WECC wishes to continue to use a similarity <br />index, the growth form categories must be altered for several reasons. <br />A. Comparison of growth form categories as widely defined as those <br />outlined in Table 1 of Exhibit 4.6.1 .A does not comply with the <br />intention of the species diversity standard. An important part <br />of diversity is that there are several species represented within <br />one or more growth form groups. For instance, it is ecologically <br />significant that a certain number of perennial native grass species <br />fairly evenly contribute to the community composition, especially <br />with regard to the dry meadow areas. This species composition is <br />important and should somehow be reflected in the comparison. Hence <br />it may be important to make certain categories more specific. An <br />example is shown below. WECC and the Division should further <br />negotiate this issue. <br />Annual Forb <br />Perennial Forb with highest relative cover <br />Perennial Forb with next highest relative cover <br />Other Perennial fortis <br />Perennial Native Grass with highest relative cover <br />Perennial Native Grass with next highest relative cover <br />Other Perennial Native Grasses <br />Etc. <br />