2008-05-29_GENERAL DOCUMENTS - C1981008

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Pagel of 2 Mathews, Dan From: Mathews, Dan Sent: Thursday, May 29, 2008 1:41 PM To: 'Shawn Conner' Cc: greg@lewicki.biz; Ross Gubka (rgubka@wfcnucla.org); Brown, Sandy; Talvitie, Marcia Subject: RE: WFC NH-2 2008 Veg Analysis Plan is \J.9 Sam?l?n? Shawn: Thanks for the reminder. The sampling plan was in a stack "to do" but not at the top. Anyway, I did just now look the plan over. There are a couple minor issues that need to be clarified, and 1 significant concern that I have. The significant concern I have is with the plan to include the 21.2 acre "first year Phase 3 Irrigated Pasture area" in the same "sampling universe" as the 130.1 acre "second year Phase 3 Irrigated Pasture area", for bond release success demonstration. This seems illogical and contrary to regulatory intent, and does not conform with Division guidelines and past precedent. The approach is not acceptable. Logical units for Phase III bond release need to be defined at the outset, and remain the same throughout the multiple year success demonstration period. The same 130.1 acre irrigated pasture block for which success was demonstrated last year will need to be sampled again this year, and success will need to be demonstrated for that block based on adequate sampling of that block by itself either this year or in the next couple years, in order for it to qualify for Phase III bond release. We can't have a revolving door situation in which the block sampled for final bond release changes between 1st year sampling and subsequent year sampling. Separate sampling blocks will need to be established for the Year 2, 130.1 acre block, and the Year 1, 21.2 acre block (if the operator wishes to go forward with the 21.2 acre block sampling this year). The minor concerns, which need to be clarified, include the following: 1. In Section 1.0, first paragraph, "2 out of 3 consecutive years" should be "at least two of the last four years of the liability period", pursuant to Rule 4.15.7(5). 2. In Section 2.2, Paragraph 4, the phrase "until either sample adequacy is reached ...or a minimum of 15 to 30 samples is reached, depending on the statistical methods to be used" could be interpreted to mean that an adequate sample size could be obtained with fewer than 15 samples, or without meeting sample adequacy, as long as a minimum size of 15 is met (neither of which is the case). Since the details regarding sample size determination are spelled out in Section 2.3, 1 would recommend that the first sentence of Section 2.2, paragraph 4 be revised to state "For both cover and production, sample size will be determined as specified in Section 2.3, depending on the statistical methods to be used". 3. Under Definitions on page 5, please verify that the criteria/definitions are consistent with the approved permit and last year's (Year 1) sampling. Note, the 10% allowance regarding annuals is addressed in the 1995 Bond Release Guidelines, and is based on relative cover, not absolute cover. 4. In the first sentence under Section 2.3, 1 would recommend that the statement "A minimum sample size of 15 is required at each site" be replaced with "A minimum sample size of 15 or 30 will be required, depending on the comparison methodology employed, as addressed below". 5. In Items 1 and 2 under "Comparison of Measured Parameters", on page 6, 1 would recommend that "and sample size of at least 15 is met", be inserted after "if sample adequacy is achieved". "Mean" in both cases in Item 1 and in the first sentence of Item 2 should be "Sample Mean". 6. Under Item 3, reference to the "Equation 2" t-test is not correct and needs to be revised. See the formula in Rule 4.15.11(2)(c); the numerator terms for the "reverse null" test are reversed compared to the "Equation 2" test. Also "mean" in the second sentence of Item 3 should be "sample mean". Also, under the Item 3 approach, should 5/29/2008