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Ill. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />densities, and exhibits the some low vigor as noted in Mining Area #1; winterfat and scarlet <br />globemallow are also present in the stand. Despite the relatively low perennial cover, no rills or <br />gullies or other indicators of erosion were observed. <br />Reference Areas <br />Each of the two grassland reference areas (GREF-North and GREF-South) and each of the two <br />sagebrush reference areas (SREF-A and SREF-B) were observed. <br />The Northern grassland reference area (GREF-North), is a couple acre triangular grassy patch <br />dominated by needle and thread and blue grama, with a component of cheatgross and <br />scarlet globemallow. Dave Andrews commented that there is more cheat grass now than when <br />the baseline vegetation survey was done. <br />The Southern grassland reference area (GREF-South), is a long relatively narrow grassy r?dgeline <br />dominated by needle and thread, with lesser component of blue grama and scarlet <br />globemallow, and some cheatgrass, though the extent of cheatgrass cover appeared to be <br />lower than at the northern grassland reference area. Widely scattered big sagebrush and four- <br />wing saltbush shrubs are also present. <br />The southern sagebrush reference area (SREF-A) appeared to be a good condition sagebrush <br />rangeland area, with a productive understory of blue grama and needle and thread, along with <br />scattered native forbs and prickly pear cactus. The northern sagebrush reference area (SREF-B) <br />appears to exhibit a higher density of sagebrush, with a significant bare ground component in <br />the spaces between sage plants. Bottlebrush squirreltail is the dominant grass, with a high <br />percentage of the grass cover comprised of clumps beneath the sagebrush shrubs. Other <br />species present include sand dropseed and scattered cheatgrass. <br />Bond Release Vegetation Sampling <br />A preliminary sampling plan for Phase II/Ill bond release was presented in the operator's initial <br />Phase II application submittal dated October 29, 2009. Due primarily to the fact that portions of <br />the Phase II request area was not sampled, and reference areas were not adequately sampled, <br />the Division has requested that statistically adequate revegetation sampling for Phase II release <br />be completed during the 2010 field season (see DRMS letter dated 27-May-2010). There are <br />certain details regarding the sampling plan and success demonstrations that need to be <br />clarified before the sampling is conducted. These issues include the following: <br />• Due to a north/south oriented pattern created by apparent alternating strips of higher and <br />lower vegetative cover across Mining Area # 1, observed by the Division in recent aerial <br />photos, the Division requests that the systematic sample design be revised. The design <br />layout and orientation of transects should be off-set from the original north/south orientation, <br />or the sample design should be otherwise altered, to ensure that sample results will not be <br />Nomilton Mine C-1991-078 3-Jun-2010 <br />-3.