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Phase II Bond Release Application SL-3 <br />Response to Adequacy Comments <br />Page 2 <br />b) Two large revegetation parcels (98-1A and 99-1F) that were included by SCC within BRB4, in the SL-3 Phase II Bond <br />Release request area (SL 3 Exhibit B, Revegetation Area-1997 Thru 2003), were not included in the BRB4 sample <br />universe depicted on Map 4 of the ESCO report. As a result, these parcels were not sampled nor were they potentially subject <br />to sampling. The combined acreage of the two parcels is 173.3 acres (from permit Map Exhibit 13-13.1), roughly 113 of the <br />total BRB4 acreage as delineated on SL-3 Exhibit B. <br />c) An argument might be made that data from the 18 transects that were located within SLr3-BRB-4 parcels, could be used to <br />demonstrate vegetation cover success or those portions of the ESCO Map 4-BRB4 sample universe located outside of the <br />East Wadge Exclusion area. The Division has considered this, but based on our assessment of the data, it appears that the <br />sample site of 18 would be insufficient to allow for a statistically valid demonstration of success. <br />We performed a detailed review of the SL-3 vegetation cover data, and generated DRMS Tables 1 through 4 (enclosed), from <br />the individual transect data presented in SL-3 Attachment E. DRMS-Table 1 perrains-to the MountahirBmsh Reference <br />Area, Table 2pertains to the Sagebrush Reference Area, DRMS Table 3pertains to the BRB4 cover data for the Twenty- <br />four (24) transects included in the SL-3 application, and DBMS Table 4 presents cover data and statistics for the eighteen <br />(18) BRB 4 transects located outside the East wadge Exclusion Area. While t-test comparisons indicate that the reclaimed <br />area allowable herbaceous cover mean (adusted sample mean = 28.6%) is not less than 90% of the weighted refervnce area <br />herbaceous sample mean (standard = 31.9%), the test it not statistically valid, pursuant to Rule 4.15.11(2)(a) because the <br />minimum sample si-e requirement was not met. Application of the required sample adequacy formula to total vegetation cover <br />data for the 18 transects resulted in a minimum required sample size of 23, while application of the formula to herbaceous cover <br />data for the 18 transects resulted in a minimum required sample size of 22. <br />In summary, out concerns regarding BRB-4 cover success demonstration are that (a), data from six <br />transects located outside of the bond release request area were improperly included in the <br />demonstration; (b), a major portion of the BRB-4 release request area was not included in the <br />vegetation sample universe; and, (c), sample adequacy was not achieved, when evaluation based <br />solely on data from the 18 transects located inside the bond release request area. <br />Please give consideration to these identified deficiencies, review the information and conclusions <br />presented in the enclosure tables, and provide response, explanation, and proposed course of <br />action as appropriate. Based on the information we have reviewed, it would appear that either SCC <br />will need to revise the application to remove BRB4 from the release request area, or the Division <br />will issue a partial approval, with BRB-4 excluded from the approval <br />Response: Based on the deficiencies identified by CDRMS for BRB-4, SCC requests BRB-4 be removed from <br />Phase II Bond Release application SIr3 under consideration at this time. In addition, SCC requests that CDRMS <br />issue a partial approval of the SL-3 application to approve Phase II bond release for BRB-2 and BRB-3. A BRB-4 <br />Phase II application will be submitted in the future and with consideration of CDRMS comments in the SL-3 <br />adequacy review letter. <br />2. The Division noted that in the revegetation success demonstration sections of the application, statistical sample adequacy for <br />vegetation cover was demonstrated only for total vegetation cover, and not for herbaceous cover vegetation cover. This is consistent <br />with the methods with the method specified in Appendix 13-13 of the approved permit. However, because herbaceous <br />vegetation cover is the ba is for the cover success standard, it would be appropriate for sample adequacy to be demonstrated based <br />on herbaceous cover, as well as total vegetation cover. <br />Please address this concem, and unless appropriate justification is provided, please commit to <br />timely revision of the approved permit to specify that sample adequacy will be demonstrated for