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envisioned in the current permit. Transect lengths, quadrat sizes, and other aspects of the design as described in Section 2.1 narrative and depicted in Figure 1 of the report differ in various specifics from the methods described on pages 13i and 13ii of the permit. In general the sample layout as described in the report is acceptable for bond release success demonstration sampling, and the systematic design described does have certain advantages over the simple random design. One issue regarding the layout needs to be clarified, with respect to sample size. In a random design, once sample adequacy has been demonstrated, and the relevant minimum sample size achieved, additional sample plots or transects aze not necessary. However, in a systematic design, further sampling is required if sample adequacy/minimum sample size is attained, but sample observations have not been made at each of the pre-selected systematic grid points laid out for the sampled parameter. Further, if sample adequacy has not been achieved upon completion of sampling at each of the initially established grid points, a second systematic grid must be established, with the necessary additional sample points uniformly distributed within the sampled pazcel (under the standazd null framework, where sample adequacy is required). These details do not appear to be cleazly described in the report, and the protocol should be clarified in this regazd. Please modify the protocol to clarify these details in the amended section to be incorporated in the permit. 3. Section 2.2 of the report describes the cover sampling method employed. The method employed is generally consistent with the point intercept method described, although the transect length is shorter, and transects were systematically rather than randomly distributed within the sampled pazcels. These differences aze not significant, and the approach described is generally an improvement over that described in the current permit. A potentially more significant departure from the approved plan, is that the approved plan describes a "multiple hit" cover sampling approach, with "hits" on additional vegetation species below the "first hit" to be recorded sepazately. The approved plan indicates that "first hits will be used to calculate total absolute percent cover. "All hits" will be used to calculate relative cover or frequency." This approach is in accordance with the recommended procedure described on page 7 of the Division's October, 1988 Land Use and Vegetation Guideline Document. The method employed in the 2004 sampling, and proposed for bond release sampling in the 2004 monitoring report is a "first hit" point sample method, with no provision for recording of additional species that might occur beneath the plant initially encountered. Given the relatively low cover contribution by woody plant species, it does not appear likely that species composition calculations would be significantly impacted by a "multiple hit" sample approach, as opposed to the "first hit" approach proposed. The cover sample method described is acceptable, but will need to be addressed in the amended sampling section to be incorporated into the permit.