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Plant Cover. Plant cover was evaluated by sampling along the outstretched 50-meter transect <br />tape. Along the outstretched tape, a total of ten previously identified and randomly selected <br />intervals were used as the sample locations for sampling. These ten points were then used as the <br />sample locations for collecting plant cover. At each designated sample point, an inclined metal <br />ten-point flame, one meter in height was positioned perpendicular to the tape and a sharpened <br />metal rod was dropped. Each sampling point was sampled at ten-centimeter intervals along the <br />ten-point frame. Even numbers were sampled on the right-hand side of the tape and odd numbers <br />were sampled on the left-hand side of the tape. <br />Each observation was recorded as to the specific plant species encountered as the rod was <br />dropped. If no plant cover was encountered, then the observation was recorded as to the presence <br />of plant litter, rock, bare ground, lichens or cryptograms. Plant material produced in the 2009 <br />growing season which was still attached to the plant was considered as living plant material and <br />all plant material produced in prior years or which had fallen to the ground was considered to be <br />litter. The 100 data points collected along each transect were then summarized into a single <br />datum for purposes of statistical analysis. Absolute and relative plant cover, species diversity, <br />and plant life forms were determined based upon the observations collected in sampling the plant <br />cover. <br />As outlined in the Kerr Permit and as approved by the Division, the plant cover standard at the <br />Marr Mine is based on a total cover standard, which means that all plant cover including annual <br />and biennial plants and listed noxious weeds are sampled and counted toward the cover standard. <br />At the Marr Mine, the reclamation cover and production success standards are based on <br />reference areas standards, wherein the potential revegetation success standards are based upon a <br />"weighted average" value based upon the acreage of each vegetation type disturbed by mining. <br />However, since a comparison of the pre-mining vegetation map documents that all of the area <br />associated with the 1999 Reclamation Block is associated with the Alkali Sagebrush Vegetation <br />Type; approval was obtained from the DRMS to sample only the Alkali Sagebrush Reference <br />Area and use these data as the revegetation success standard. Therefore, the values for plant <br />cover and production obtained from the sampling of the Alkali Sagebrush Reference Area were <br />the standards used to calculate an overall success standard for these two parameters. <br />Production. On all of the Reclamation Blocks and Reference Areas sampled, a simple random <br />statistical sampling approach was used. Within the boundaries of the designated area being <br />sampled, all production clip plots were randomly located and along each transect, and a total of <br />three randomly located one-quarter square meter circular plots were clipped. The three plots <br />were clipped by life forms for perennial grasses and perennial forbs. The Kerr Permit states that <br />production will be based upon total production, which includes annuals and noxious weeds, but <br />these two plant life forms were not found in the production sampling. 'this was the same transect <br />used for cover and shrub density sampling. The three clip plots were then averaged into a single <br />transect datum for purposes of statistical analysis. Since the Division's Vegetation Guideline <br />recommends that annuals and biennials, noxious weeds and shrub production are typically not <br />clipped, but since the Kerr Permit requires that the production revegetation success standard is <br />based upon "total herbaceous production" we intended on clipping all annuals, biennials and