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cover and aze valuable components of the community, but they aze not included in the WPD values for the comparison to the <br />reclamation standazd. Review of the baseline data do not End sub-shrub species counted in the baseline woody stem values. <br />Overall the proposed sampling plan agrees with the Regulations, Guidelines and Edna Permit Commitments with the <br />following exceptions: <br />Transect length for Cover and Diversity data collection needs to agree with the Edna permit (page 4.423) <br />commitment of LOOM long. <br />2. The appropriate adequary formula needs to be applied to the data as defined in the Division's "Guideline Regazding <br />Selected Coal Mine Bond Release Issues" (Apri118, 1995, pages 20 and 21). If the data show that the sampled <br />parameter is less that the reclamation standazd, please use the adequary formula shown on page 20 of the referenced <br />guideline. If the reclaimed azea sample data equal or exceed the reclamation success standard, the adequacy formula <br />shown on page 21 of the referenced guideline is applicable. <br />3. Sub-shrub spedes should not be included in the stem counts for Woody Stem Density reclamation success <br />determinations. <br />The Division appreciates the operator submitting reclamation success sampling proposals to the Division fox review prior to <br />data collection. This practice allows for concerns with the sampling plan to be corrected prior to the data collection in the <br />field. When P&M knows of the planned sampling schedule, please apprise the Division of the timing of the sampling. The <br />Division often attempts to observe the state of the mine and vegetation concurrent with the sampling program, and if <br />possible, meet the sampling crew on site. If questions arise in the field these questions are ofren able to be addressed by <br />Division personnel at the time of the inspection. <br />