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a) On page (e)-24, the second paragraph should be amended to clarify that equality is <br />defined as "90% of the approved standard". We would recommend the first two sentences <br />of the paragraph be reworded as follows: <br />For either method, revegetation will be deemed adequate if herbaceous <br />production in the reclaimed block is equal to or greater than (90% oj) the <br />standard of 1.84 tons per acre in at least 2 of the last 4 years of the liability <br />period, in conformance with DRMS Regulation 4.15.9. If the total harvest <br />measurement method is used, statistical comparison is not appropriate; the <br />reclaimed block production as measured by the total harvest method must <br />equal or exceed 90% of the standard, with no statistical confidence interval. <br />b) On page (e)-25, the first sentence of each paragraph should be amended for clarity. <br />Paragraph 1, Sentence 1, should state: During field sampling for production, at least 15 <br />sample observations will be made within each bond release block. Paragraph 2, Sentence <br />1, should state: Reclaimed area production will be compared to an approved technical <br />standard, as described below. Paragraph 3, Sentence 1, should state: 1) If sample <br />adequacy exists at the reclaimed site, and the production sample mean is equal to or <br />greater than Q, no statistical comparison is necessary and production at the reclaimed site <br />will be deemed successful. Paragraph 4, Sentence 1, should state: 2) Ifsample adequacy <br />exists at the reclaimed site, and the production sample mean is less than Q, a "standard <br />null" one-sided t-test with alpha error probability of 0.10 will be used, in conformance <br />with DRMS Regulation 4.15.11(2)(b), using the general form of the one-sided t-test as <br />follows: <br />c) On page (e)-26, a couple changes to the second narrative paragraph are warranted, due <br />to erroneous mention of reference area in the first sentence, and because the wrong t-test <br />formula is referenced in the final sentence. We recommend the following: 3) If sample <br />adequacy is not achieved, and the following 2 conditions are met: 1) a minimum of 30 <br />sample observations were taken at the reclaimed site and 2) the production sample mean is <br />greater than Q, a "reverse null " hypothesis will be tested using a one-sample, one-sided t- <br />test with alpha error probability of 0. 20, in conformance with DRMS Regulation <br />4.15.11(2)(c). The t-test formula used would be the formula listed in Rule 4.15.11(2)(c), in <br />which the numerator parameters from the formula shown above are reversed <br />d) The statistical methodology associated with the two sample reverse null testing <br />procedure on page (e)-27 and continuing to the section headed "Irrigated Pasture Type" on <br />page (e)-28 is not applicable for Cropland success demonstration, since reclaimed area <br />production is compared to a technical standard rather than a reference area. As such, two- <br />sample testing is not appropriate, and the entirety of the section presented under Method 4, <br />beginning on page (e)-27 should be deleted. <br />6. Discussion of the proposed reference area for the Irrigated Pasture Type is presented on <br />pages (e)-29 through (e)-34, location and boundaries are shown on Map 3.02.2-10, and a <br />detailed delineation of soil types and associated acreages within the reference area is <br />presented on Map 3.02.2-11. Cover and Production data from the summer 2007 reference <br />3