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2010-05-26_REVISION - C1981008 (2)
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2010-05-26_REVISION - C1981008 (2)
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Entry Properties
Last modified
8/24/2016 4:12:29 PM
Creation date
7/6/2010 1:41:54 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
5/26/2010
Doc Name
Preliminary Adequacy Review
From
DRMS
To
Western Fuels-Colorado
Type & Sequence
SL12
Email Name
MLT
SB1
Media Type
D
Archive
No
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C- 1981 -008 - SL -12 26 May 2010 <br />Preliminary Adequacy Review Page 5 of 7 <br />demonstrate success. The fact that no adjustment was applied results in a more robust <br />demonstration of success, because the adjustment factor would have lowered the <br />reference area production standard (making success demonstration less stringent). <br />8. We have the following requests regarding the pages replaced in March 2010, pertaining <br />to Post -mine Revegetation Success: <br />a) Pages 26, 27, and 28 of the original application were replaced with 4 pages of revised <br />material. The replacement pages were erroneously numbered 27, 28, 29, and 30. The <br />replacement pages should be numbered 26, 27, 28, 28a, and 29. Please submit <br />correctly numbered and dated revision pages for insertion into the application. <br />b) Table 1 on the replacement pages is confusing and contains erroneous information. <br />The table would be easier to read if the information for each reference area sample <br />were immediately followed (on the next row of the table) by the information for the <br />relevant reclaimed area sample. Second, the column at the far right side of the table <br />with the heading "Adequacy Demonstrated" is confusing. The intent of the column <br />appears to be whether "Success" was demonstrated, rather than sample adequacy. <br />The asterisked footnote stating "adequacy demonstrated via ... West" contributes to <br />the confusion, because a t -test is used in demonstration of success, not demonstration <br />of sample adequacy. Lastly, it is not clear whether the "Yes" statements and asterisk <br />or lack of asterisk notations are intended to apply to the cover factor or the production <br />factor or both. Please revise the table to present the reference area and corresponding <br />reclaimed area sample information in logical order. Further, please insert a column <br />titled "Cover Success Demonstrated" within the "Absolute Cover" block of the table, <br />and re -title the "Adequacy Demonstrated" column on the far right side of the table <br />"Production Success Demonstrated ". Please delete the confusing "adequacy <br />demonstrated..." footnote. <br />c) The Mean and 90% of Mean values listed in the Absolute Cover block of the table for <br />various categories are erroneous; IP Reference Area 2007 values should be 75.2% <br />and 67.7% respectively, DP Reference Area 2007 values should be 30.3% and 27.3% <br />respectively, and IP Reference Area 2008 values should be 57.8% and 52.0 %, <br />respectively. Please revise the table with the correct values. <br />d) The next to last narrative paragraph on revised page 28 (beginning with Irrigated <br />Pasture cover in the reclaimed area...) is confusing and contains inaccuracies; it <br />should be deleted. <br />e) Inclusion of the final narrative paragraph on the page, the subsequent t -test, and <br />related paragraphs on the following page is unnecessary, and merely repeats <br />information that is adequately covered in Appendix B. A simpler approach would be <br />to asterisk the "Yes" notation for the 2007 Dryland Pasture Reclaimed Area Cover, <br />with a footnote to refer the reader to the t -test success demonstration in the applicable <br />section of the Appendix B, BIO -Logic Phase 3 Vegetation Report (Section 3.3, pages <br />14 -16). The entire narrative after the initial paragraph below Table 1 could be <br />replaced with a statement referring the reader to the BIO- Logic, Inc. report in <br />Appendix B, "2007 -2008 Vegetation Studies for Phase 3 Bond Release... ", for a <br />
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