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alternative to the total count/census approach described in a later section of the <br />report, for bond release woody plant success demonstration. <br />Please take these comments into consideration in preparing the amended <br />success demonstration/ sampling/ statistical evaluation section to replace the <br />narrative on current pages 113ii and 113iii. <br />6. Section 3.1 of the report discusses the fact that the reclaimed azea as well as <br />adjacent azeas have been subject to extensive grazing pressure over the yeazs, and <br />that sheep aze trailed through the azea in late spring each year. During the DMG <br />inspection it was obvious that both the reclaimed azea and the grassland reference <br />azea had been subject to significant elk grazing earlier in the spring. Presumably, <br />the elk have by now migrated to higher ground for the most part, and vegetation <br />will have the opportunity to make substantial growth prior to sampling in late <br />May. <br />It is important that bond release sampling be conducted prior to seasonal sheep <br />grazing, or that other measures be taken to ensure that sheep aze not grazed on the <br />reclaimed or reference azeas prior to sampling, such that the validity of the <br />sampling results would be compromised (Rule 4.15.5(2)). The sampler will <br />need to assess and document that grazing has not interfered with or <br />compromised the sampling effort prior to initiation of sampling, and such <br />assessment/documentation will need to be included in the bond release <br />submittal. <br />7. Narrative in Section 3.2.1 addresses sampling results for the reclaimed grassland <br />azea. It notes that the azea exceeds the woody plant density standazd of 90 stems <br />per acre (90% of 100) by direct comparison, but "cannot pass the rigors of <br />statistical testing due to the inherently high variability of the data set " The <br />recommendation in the report is to conduct a total shrub count within the 12.6 <br />acre reclaimed grassland community, to allow for a direct comparison success <br />demonstration. This approach is acceptable under the current rules, and has been <br />approved for woody plant density bond release demonstration on at least one <br />occasion. The approach is not specifically authorized under the Division's <br />recently approved revegetation program amendment, which we anticipate will be <br />approved by MLRB for incorporation in DMG Coal Regulations later this yeaz. <br />The approach can still be approved under the current rules. If the total shrub <br />count is to be employed for bond release demonstration, the protocol to <br />ensure accuracy and prevent "double counting" of individual shrubs, will <br />need to be described within the amended success demonstration/ sampling/ <br />statistical evaluation section to replace the narrative on current pages 113ii <br />and 113iii. An alternative approach for consideration would be the non- <br />statistical direct comparison "sample size 75" approach specified in <br />4.15.11(3)(b)(i) of the recent DMG revegetation program amendment. <br />