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Mike Boulay -16- April 11, 2011 <br />adequacy was achieved, cover sampling stopped. On this site, the subsequent <br />transects were sampled based upon which transect was located closest to the <br />end of the transect being sampled. Given the fact that the transect location and <br />bearing was randomized the location of the closest transect to this point would <br />also have to be considered as being random. Examination of Map 2.04.10-3, <br />Rhino Energy LLC, Fruita Unit Train Loadout - Greasewood Reference Area, <br />clearly documents that the transect locations were randomly located and <br />sampled on this site. Therefore, there was no bias, due to sample transect <br />location. <br />The DRMS appears to take exception with this approach by saying that their <br />"assumption is that the transects would be numbered in accordance with the <br />sequence selected" and requests that documentation be submitted explaining <br />how "transect selection was unbiased, and explaining why cover data was not <br />obtained from sequentially numbered transects ... " <br />Rule Section 4.15.11 (1) states that "all aspects of the vegetation sampling <br />program must be conducted to ensure a reasonable, unbiased estimate of the <br />appropriate population parameter. Consistency in sampling shall be required in <br />comparison between the reclaimed area and the undisturbed area. Both <br />random and systematic sampling designs are acceptable." The Vegetation <br />Guideline on page 5 states "it is important that unbiased samples be obtained. In <br />general, the Division recommends that transect samples be randomly <br />located." By definition, randomization means that every individual in the <br />population has an "equal chance of being selected" with the sample area. The <br />DRMS comments are confusing in that they suggest that unless "sequentially <br />numbered transects" are sampled there will be bias in the sampling effort. <br />It would appear that the comments contained in the contained in the Division's <br />adequacy response letter are inconsistent with the regulations, Vegetation <br />Guideline and definition of "randomization" as defined in numerous statistical <br />references examined. In a classic statistical treatise, written by D. R. Cox <br />entitled "Planning of Experiments" published by John Wiley & Sons in 1958, he <br />defines "randomness" as consisting of a situation where "there is no recognizable <br />pattern." He further states on page 27 that "the order in which plots [transects] <br />are cultivated or harvested would ordinarily be assumed negligible ... and that <br />the best procedure ... to test ... from one block [is] in random order. . . " <br />Thus, it is irrelevant, if the transects are sampled in ascending or descending <br />order or any other random order. This text further states [page 71 ] that one <br />should "choose a starting point in a haphazard way without looking at the <br />[random number] tables" while the DRMS herein appears to be saying that <br />random numbers can only be used if a "systematic sampling" approach is used <br />by starting only at row one, column one and then only if random numbers are <br />collected from "sequentially numbered" rows and columns. This approach is