2010-10-27_REVISION - C1980005 (2)

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The revised text is still quite confusing, and contains internal inconsistencies as well as inconsistencies with Appendix 13-13. For example, the cover standard as presented in Appendix 13-13 is 90% of TWICE the weighted reference area first hit herbaceous vegetation cover. Certain sections of the relevant narrative in the amended text are consistent with this criterion, but subsequent sections make reference to "all hit" herbaceous cover rather than "first hit" herbaceous cover. Statistical formulas are largely consistent with corresponding formulas presented in Appendix 13-13, but there are certain discrepancies which result in a lack of clarity. If the intent is that the revegetation success criteria and sampling/statistical methods for demonstration of success are to remain largely consistent with those set forth in Appendix 13- 13 (which appears to be the case), then we have the following recommendations. a. Delete the extraneous section heading "Revegetation Success Sampling and Evaluation", and underline "2.05.4(2)(e)(vi) Determining Revegetation Success" to denote that it is a major section heading. The reference to Appendix 13-13 should be moved to become the second sentence of the third paragraph in the introductory text under the 2.05.4(2)(e)(vi) section heading, but should be modified as follows: The plan presented in Appendix 13-13 Vegetation Evaluation Procedures for Testing Reclamation Adequacy for Phase III Bond Release, remains in effect, with the exception of certain clarifications presented in this Section 2.05.4(2) (e) (vi) of Volume 14. Sampling and statistical methods and success criteria for vegetation cover for Phase II bond release are consistent with the methods and criteria described for Phase III bond release, with the exception that vegetation cover success for Phase II release requires data for only a single year. It is important to note that vegetation sampling for bond release success demonstration for the Seneca II permit area will be conducted completely independent of vegetation sampling for bond release success demonstration in the adjacent Sage Creek permit area (which was originally apart of the Seneca II permit area). This means that any Phase II or Phase III bond release applications for the Seneca II permit area will be supported by statistically valid vegetation data. collected from reclaimed lands contained entirely within the boundary of the Seneca II permit area approved in PR-2. Appendix 13-13 revegetation success demonstration methods and success criteria which are referenced in permit Volume 14 are applicable to the Seneca II permit area as approved in PR-2. Revegetation success demonstration methods and success criteria applicable to the adjacent Sage Creek permit area (portions of which were within the original Seneca II permit area as it existed prior to PR-2) are addressed in the applicable sections of Permit C-2009-087. b. .83% and .17% in the second paragraph of the introductory section of 2.05.4(2)(e)(vi) should be changed to 83 % and 17% respectively. c. Add a new paragraph at the end of the 2.05.4(2)(e)(vi) introductory narrative which states: All disturbed lands within the reduced permit area fall within Bond Release Block 3 (BRB- 3) or Bond Release Block 4 (BRB-4). A summary of sampling designs and success