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GENERAL43132
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Last modified
8/24/2016 8:11:56 PM
Creation date
11/23/2007 12:13:00 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980005
IBM Index Class Name
General Documents
Doc Date
3/17/2005
Doc Name
Phase II/III Bond Release Vegetation Proposal Review Letter
From
DMG
To
Seneca Coal Company
Permit Index Doc Type
Vegetation
Media Type
D
Archive
No
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category area"). As such, the statement that "twenty samples will be located in the high density <br />patches" means that a minimum of twenty transects would be placed in the high density category <br />area. Transects would not be randomly distributed within the category area, but would be <br />proportionally distributed within the individual patches that comprise the category area, with <br />transect locations randomly located within discrete patches (stands). Please confirm if this is <br />the correct interpretation, or clarify the intent if this is not the correct interpretation. Also, <br />please give consideration to the alternative sampling approach described in (c) above. <br />e) As we discussed at the meeting, subshrubs (i.e. half-shrubs or suffrutescent species) should <br />not be counted as woody plants. They should instead be included as "herbaceous" for cover and <br />production success evaluation. Please amend the proposal accordingly. <br />f) In the sample adequacy formula on page 15, we interpret "vegetation type" to be synonymous <br />with "density category area" for the purposes of this proposal. Please amend the wording to be <br />more specific. <br />g) An alternative, and perhaps simpler and more effcient approach to success evaluation as <br />stated on page 16, would be: <br />A woody plant density standard of 1000 stems per acre will apply to the mapped "high density <br />patch category area'; and this category area will comprise at least 5% of the BRB area. On the <br />remainder of the area, a woody plant density standard of 100 stems per acre will apply. Separate <br />success demonstrations for each of these areas will be made in accordance with applicable <br />statistical sample adequacy and testing procedures of proposed rules 4.15.11(2) or 4.15.11(3). <br />Please consider this alternative approach for woody plant density success evaluation. <br />h) As we discussed at the meeting, shrub data will need to be collected and success <br />demonstrated in two consecutive years, for Phase III bond release. The statement on page 16 <br />that "shrub data will be collected during one year only", will need to be withdrawn. <br />
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