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i. <br />Mr. Bryan J. Archer - 2 - <br />5. There is no comparison between 1988 data and <br />collected two years ago. Such a comparison <br />April b, 1989 <br />the results of data <br />and trend analysis would <br />prove useful in evaluating revegetative progress. <br />The permit application (pages 334 and 335) states that for herbaceous <br />cover and production, "Re vegetation will be considered successful...when <br />the percent total...for the reclaimed area is greater than or equal to <br />90% of the total...measured for the reference area at an 80% <br />confidence". Rule 4.15.8(3) states that "For herbaceous cover the <br />revegetated area should be considered acceptable if it is not less than <br />90% of the cover as determined from the reference area or approved <br />standard with 90% statistical confidence". Rule 4.15.8(4)(a) states the <br />same standards as 4.15.8(3) but is in relationship to herbaceous <br />production. SCC should revise the permit application to conform with the <br />approved rules through the minor revision process. <br />CMLRD sampling indicates that the average vegetation cover is 37.5% as <br />compared to 85.3% in the Seneca II Mountain Brush reference area. Vegetation <br />cover values range from a high of 43.6% in the Steep Upland area to a low of <br />33.6% on the Bench areas. Total vegetative cover is not yet meeting the cover <br />success criteria as stated on page 334 of the permit application. The <br />herbaceous diversity requirement (page 335, last paragraph) is being met on <br />the Bench areas. Diversity success standards are not being met on the Steep <br />Upland areas because Hard sheep fescue's (Festuca ovina) relative cover is <br />greater than 40%. The diversity success s an ar s are not being met on the <br />1981 re vegetation and Upland areas because the sum of the five perennial <br />species with greater than 3% relative cover in both areas exceeds 75%. Woody <br />plant density and diversity success standards were not being met at the time <br />of sampling in any of the pit areas. <br />We hope that these comments will be helpful to you. If we can be of further <br />assistance, please contact us. <br />Sincerely, <br />~~ •~~ <br />J. M. Clayton <br />Reclamation Specialist <br />JMC/scg <br />5009E <br />