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• Herbaceous cover was recorded from 25 'fiicroplots" (20 x 50 cm) spaced <br />at one meter intervals along a 25 meter length transect. Shrub cover was <br />estimated by measuring canopy intercept per species. Ore transect <br />represented one sample. Inherent in this scientific system is the <br />possibility of shrub cover exceeding 100 percent. Herbaceous cover may also <br />exceed 100 percent by itself or herbaceous cover plus shrub cover may exceed <br />100 percent. This occurs because the cover of each plant species is <br />~ estimated separately irrespective of overlap, which occurs when small plants <br />grow under large ones. <br />Northern does not see a potential inconsistency with pre- and post- mining <br />data as the same quantitative system will be used to estimate vegetation <br />cover on the reclaimed area. <br />As ,jointly decided by CMLR and Northern at the June 26, 1981 meeting, the <br />reference area concept is not being used to measure revegetaticn success. <br />It should be pointed out that Northern will ask far a variance far woody <br />plant density. Thus, the data summaries far total herbaceous cover are <br />a appropriate as presented. Sample adequacy was calculated assuming that each <br />transect was one sample unit. <br />fie possibility of herbaceous cover plus litter totalling more than 100 <br />is real because using the Daubenmire approach to sampling, cover by <br />individual species is estimated. Overlap by plants aver litter, or plants <br />• ~ ove~nlantc_. can Lead-to-total_~o~[er fioures in excess of 10 ~;. Familiarity <br />with plant ecological literature, and the forms that cover data may take, <br />would reveal that summation to 10[6 does not result from the most commonly <br />used techniques. While current experience in the use of cover data as <br />revegetation success standards shows the desireability of the simple measure <br />of absolute canopy cover (adds to 100K), the individual species approach <br />used here is better established in the literature of plant ecology and is <br />perfectly useful pro vidirg the same methods are used in testing for <br />re vegetation success as Northern certainly intended from the beginning. <br />Pursuant tc the Meeting with CMLR staff held on June 26, 1981, Northern <br />Coal Oompany requests CMLR to stipulate the methods to be used to determine <br />cover production assuming Northern will use the baseline vegetation data as <br />the standard against which to measure revegetation success. Northern also <br />requests a stipulation to establish shrub planting density at a lower level <br />than currently required in Rule 4.15.8(7). Northern further requests CMLR <br />to stipulate the adequate species diversity to be achieved required by Rule <br />4.15.8(5). <br /> <br />K-sA _ _ ~/ 7/~7 <br />