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The following adequacy issues surfaced during a review of general reclamation, <br />vegetation, and soil topics in the Blue Ribbon permit application. <br />Page 101i should be revised to identify that the truck scale facility was <br />eliminated from the permit area by Technical Revision 3. <br />2. Please indicate on page 108 the schedule at which reclamation was carried <br />out and completed. <br />The Division requests that sampling techniques listed on page 113ii be <br />revised. Specifically, <br />Cover must be estimated by a more unbiased method than an "ocular <br />estimation technique". Please revise this section of the permit to <br />address another technique, preferably the point intercept method. <br />A description of this technique can be found on pages 6 and 7 of <br />the Division's Land Use and Vegetation Guidelines. <br />Paragraph number 4 on page 8 of the above referenced guidelines <br />states the following with reference to gathering production data: <br />Standard clipping procedure is to clip either plants rooted in the <br />quadrant or to clip plants and plant parts within the volumetric <br />vertical projection of the plot. The method used must be described <br />in the application and applied consistently in all baseline and <br />subsequent sampling". <br />Please address the topic of this paragraph in the permit <br />application. <br />c. Page 113ii of the permit application states, with reference to <br />shrub density measurement, that: "Total number of stems per acre <br />will be measured through counting stems greater than 0.5 meter in <br />height in rectangular plots, 2-m x 10-m, that are randomly <br />located." The Division recommends that MINREC, INC. revise the <br />permit to include woody stems less than O.Sm in height in the woody <br />stem density counts. Furthermore, the Division recommends that <br />sample quadrants be increased from 20 square meters to 50 (50m x lm) <br />square meters. The increase in size will increase the likelihood <br />of reaching sample adequacy. <br />4. Rule 4,15.1(2)(c) has been changed, It now requires that "statistical <br />tests to be performed ... must provide results valid at the 90% <br />confidence level, using a one-sided test with a 0,10 alpha error <br />probability." Rules 4.15.8(3 )(a ), 4,15.8(4)(a) and 4.15.8(7) have also <br />been revised to require 90% statistical confidence levels on comparisons <br />of cover, production, and woody plant density respectively. Please <br />revise the "criterion" entries on page 113ii to reflect this rule change. <br />5. Page 118 of the permit application states: "Blue Ribbon will not use <br />persistent pesticides in the permit area during mining and reclamation <br />activities." Please revise this statement to reflect the present <br />spraying situation. <br />-2- <br />