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C-1981-008 - SL-12 <br />Adequacy Review No. 4 <br />5 May 2011 <br />Page 3 of 10 <br />Irrigated Pasture and Dryland Pasture areas meet the requirements of the above rule." This statement is <br />erroneous; the cited report is limited to results of vegetation sampling for the "approximately 27 acres of <br />Irrigated Pasture". Please correct the narrative in the P paragraph of page 11 to delete the reference to <br />Dryland Pasture. <br />(Item resolved with Aug. 2010 submittal) <br />The Division does not agree with the conclusion in the application narrative on page 11, that successful cover <br />has been demonstrated. The conclusion is based on incorrect interpretations of the sampling data. <br />a) The reference area was sampled in early June but the reclaimed area was sampled at least two months <br />later, sometime in August. Reference area/reclaimed area sampling should be conducted as closely as <br />possible in time, so that the stage of vegetative growth is comparable between the two areas. The <br />approved permit (as revised in TR-58) specifies that both reclaimed and reference area measurements <br />are to be made in late May to early June. The reference area comparison is not valid because the two <br />areas were sampled two months apart. Therefore, the Division recommends that the Phase II cover <br />success demonstration be based on a comparison to the technical standard (90% of 71.8%), that was in <br />effect at the time of sampling. <br />WFC revised the Phase II Irrigated Pasture comparison to an approved reclamation standard. (Item <br />resolved with Aug. 2010 submittal.) <br />b) The table on page 11 of the SL-12 application titled "Vegetation Reference Area Values" is confusing, <br />and the data is incorrect. The table presents cover sampling results from the Phase II Irrigated Pasture <br />reclaimed area, and the Irrigated Pasture Reference Area. The values presented are mean percent <br />desirable perennial cover for the reclaimed area (72.1%) and the reference area (57.8%). Please revise <br />the table on p. 11 to eliminate confusion and to provide the technical standard reference. "2008 Phase 2 <br />Release Reclaimed and Technical Standard for Cover", would be an appropriate title, and the right side <br />column heading would more accurately be stated as "Mean % Desirable Perennial Cover". Please <br />amend the table as appropriate. <br />WFC revised the table appropriately. (Item resolved with Aug. 2010 submittal.) <br />c) In the application narrative, the incorrect conclusion is drawn that cover success has been demonstrated <br />because "...reclaimed area vegetation is 124% of the reference area". The narrative references the Bio- <br />Logic reports for details of the statistical analysis. The Division does not concur that the reports provide <br />the correct 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 correct <br />statistically based comparison between the two sampling units. In the December 12 BIO-Logic report <br />documentation is provided documenting that the reference area was sampled to statistical adequacy for <br />cover in June 2008, and mean desirable perennial cover was indeed 57.8%. In the September 30 1310- <br />Logic report, documentation is provided that the reclaimed parcel was sampled to statistical adequacy in <br />August 2008, and mean desirable perennial cover was indeed 72.1%. The "Reclaimed Parcel Results" <br />section of the September 30 Bio-Logic report contains no statistically based comparison to the reference <br />area cover data, and includes the following statement: "No conclusions are drawn from these data for <br />Phase 2 studies, as they are intended to be provided to Lewicki & Associates to analyze in order to <br />determine adequacy for bond release." <br />The paragraph following the table must be amended to describe the statistical basis for the conclusion <br />that the cover criteria were achieved. In addition, the narrative must include a statement confirming that <br />the vegetation established on the reclaimed area supports the approved land use. Species composition <br />data fi-om the BIO-Logic, Inc. report would be the primary basis for the statenierit affirming that the <br />vegetation supports the approved land use. <br />This item was not addressed in the Aug. 2010 submittal, and was reiterated in the Division's March 9, <br />2011 letter. WFC's subsequent March 18, 2010 submittal satisfactorily addressed this requirement.