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B , demonstrates that "...both the Irrigated Pasture and Dryl and Pasture areas meet the <br />requirements of the above rule." This statement is erroneous; the cited report is limited to <br />results of vegetation sampling for the "'approximately 27 acres of Irrigated Pasture ". <br />Please correct the narrative in the 3 r paragraph of page 11 to delete the reference to Drland <br />Pasture. <br />2. The Division does not agree with the conclusion in the application narrative on page 11,. that <br />successful cover has been demonstrated. The conclusion is based on incorrect interpretations <br />of the sampling data. <br />a) The reference area was sampled in early June but the reclaimed area was sampled <br />at least tvwr months later, so metime in August. Reference area /reclaimed area <br />sampling should be conducted as closely as possible in time, so that the stage of <br />vegetative growth is comparable betwe the two areas. The approved permit as <br />revised in T - ) specifies that both reclaimed and reference area measurements <br />are to be made in late May to early June. The reference area comparison is not <br />valid because the two areas were sampled two months apart. Therefore, the <br />Division recommends that the phase 11 cover success demonstration be based on a <br />comparison to the technical standard (90% of 71.8%), that was in effect at the time <br />of sampling. <br />b) The table on page 11 of the SL-12 application titled ""Vegetation Reference Area <br />Values" is confusing, and the data is incorrect. The table presents cover sampling <br />results from the Phase 11 Irrigated Pasture reclaimed area, and the Irrigated Pasture <br />Reference Area. The values presented are mean percent desirable perennial cover <br />for the reclaimed area (72.1 %) and the reference area (57.8%). Please revise the <br />table on p. 11 to eliminate confusion and to provide the technical standard <br />reference. "2008 Phase 2 Release I• a lain d and Technical Standard for Cover", <br />would be an appropriate title, and the right side column leading would more <br />accurately be stated as ""Mean Desirable Perennial Cover". Please amend the <br />table as appropriate. <br />c) In the application narrative, the incorrect conclusion is dram that cover success has <br />been demonstrated because "...reclaimed area vegetation is 124% of the reference <br />area ". The narrative references the lo -Logic reports for details of the statistical <br />analysis. The Division does not concur that the reports provide the correct <br />demonstration for cover success. The reports document that sample adequacy for <br />the reclaimed area and the reference area were achieved. However, they do not <br />provide a correct statistically based comparison between the two sampling units. In <br />the December 12 BI -Logic report documentation is provided documenting that the <br />reference area was sampled to statistical adequacy for cover in June 2008, and <br />mean desirable perennial cover was indeed 57.8%. In the S eptember 30 BI -Logic <br />report.. documentation is provided that the reclaimed parcel was sampled to <br />statistical adequacy in August 2008, and mean desirable perennial cover was indeed <br />72.1. The "Reclaimed Parcel Results' section of the September 30 Bin -Logic report <br />contains no statistically based comparison to the reference area cover data, and <br />includes the following statement: <br />2 <br />