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Kent Gorham - 2 - February 11, 1994 <br />density of transects have at least one parameter (cover or production) for <br />either 1990 or 1991 which is less than the corresponding reference area value <br />for that year. <br />Additionally, CYCC states several reasons why the parcels included in Block A <br />were chosen to be released as one block. What I fail to understand is why <br />the 4.36 acre parcel located on the northwest corner of, and contiguous to, <br />parcel ODJ97-3.BR1 was not included in Block A. As you know the 4.36 acre <br />parcel was included in the recently submitted Block D bond release parcel <br />where it does not logically belong. It is the only parcel of Block D seeded <br />with seed mix No. 3 and reclaimed prior to 1981. Both of these <br />characteristics are common to parcels in Block A. I suggest we take a close <br />look at this small parcel both in the field and in bond release data to <br />determine whether an underlying problem exists here. <br />2. CYCC has responded appropriately to this comment. However, they should be <br />required to revise their sample adequacy formula on page 780-137(a) of their <br />permit. The Division has used this formula in the past but revised it during <br />1992 after identifying an error within it. CYCC should revise the value of <br />"t" in the formula. The value of "t" should change according to the number <br />of samples taken. The correct value for "t" should be taken from a <br />statistical"t" table using n-1 degrees of freedom and a 90 percent confidence <br />level (n= number of samples). The value "t"= 1.645, as used by CYCC, is only <br />valid when more than 120 samples are taken. CYCC should use the revised <br />formula for future vegetation sampling events. In the case of the Block A <br />bond release proposal, this change would not make a significant difference in <br />the Division's ability to evaluate revegetative success. <br />Additional Clarification or Revision <br />Response acceptable <br />2. Response acceptable <br />3. Response acceptable, but CYCC should explain what revision were made. They <br />just leave us guessing. <br />4. Response acceptable. <br />5. Response acceptable. <br />6. Response acceptable, but in the future CYCC should maintain and present a <br />thorough record of management practices utilized on bond release application <br />area and associated reference area(s) during the final two consecutive years <br />of reclamation liability. These records should demonstrate that the <br />reclaimed area and the reference area(s) received the same management as <br />required by Rule 4.15.7(3>(f). Records should indicate that the intensity of <br />management practices utilized were similar on the reclaim and reference areas. <br />As we discussed, CYCC should respond to these secondary adequacy review comments <br />before we offer a decision on the proposed bond release of Block A. <br />SSS/amm/9856F <br />