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C-1981-008 - SL -1 <br />Preliminary Adequacy Review <br />May 2010 <br />Page 3 of <br />Please correct the narrati e in the 3 d paragraph of page 11 to delete the reference to <br />Iryland Pasture. <br />3. The Division does not agree with the conclusion in the application narrative on page 11, <br />that successful cover has been demonstrated. The conclusion is based on incorrect <br />interpretations of the sampling data. <br />a The reference area was sampled in early June but the reclaimed area was sampled at <br />least two months later, sometime in August. Reference area /reclaimed area sampling <br />should be conducted as closely as possible in time, so that the stage of vegetative <br />growth is comparable between the two areas. The approved permit as revised in TR- <br />8 specifies that both reclaimed and reference area measurements are to be made in <br />late May to early .dune. The reference area comparison is not valid because the two <br />areas were sampled two months apart. Therefore, the Division ision recommends that -the <br />Phase II cover success demonstration be based on a comparison to the technical <br />standard 0% of 71.8%), that was in effect at the time 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 II Irrigated Pasture reclaimed area, and the Irrigated Pasture <br />Reference Area. The values presented are mean percent desirable perennial cover for <br />the reclaimed area (72.1%) and the-reference area (57.8%). Please revise the table on <br />. 11 to eliminate confusion and to provide the technical standard reference. "2008 <br />Phase 2 Release Declaimed and Technical Standard for Cover ", would be an <br />appropriate title, and the right side column heading would more accurately be stated <br />as `Mean % Desirable Perennial Cover ". Please amend the table as appropriate. <br />c In the application narrative, the incorrect conclusion is drawn that cover success has <br />been demonstrated because "...reclaimed area vegetation is 124% of the reference <br />area". The narrative references the Bio-Logic reports for details of the statistical <br />analysis. The Division sloes not concur that the reports provide the correct <br />demonstration for cover success. The reports document that sample adequacy for the <br />reclaimed area and the reference area were achieved. However,, they do not provide a <br />correct statistically based comparison between the two sampling units. In the <br />December 12 BIO-Logic report documentation is provided documenting that the <br />reference area was sampled to statistical adequacy for cover in June 2008, and mean <br />desirable perennial cover was indeed 57.8%. In the September 30 BIO-Logic report, <br />documentation is provided that the reclaimed panel was sampled to statistical <br />adequacy in August 2008, and mean desirable perennial cover was indeed 72.1 %. <br />The "eclaifned Parcel Results" section of the September 30 Bio-Logic report <br />contains no statistically based comparison to the reference area cover data, and <br />includes the following statement; <br />No conclusions are drawn from these data, for Phase 2 studies, as they are intended to <br />be provided to Lewicki & Associates to analyze in order to determine mine adequacy far <br />bond release. <br />