2011-05-05_REVISION - C1981008 - Laserfiche WebLink

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C-1981-008 - SL-12 Adequacy Review No. 4 5 May 2011 Page 7 of 10 b) Table 1 on the replacement pages is confusing and contains erroneous information. The table would be easier to read if the information for each reference area sample were immediately followed (on the next row of the table) by the information for the relevant reclaimed area sample. Second, the column at the far right side of the table with the heading "Adequacy Demonstrated" is confusing. The intent of the column appears to be whether "Success" was demonstrated, rather than sample adequacy. The asterisked footnote stating "adequacy demonstrated via...t-test" contributes to the confusion, because a t-test is used in demonstration of success, not demonstration of sample adequacy. Lastly, it is not clear whether the "Yes" statements and asterisk or lack of asterisk notations are intended to apply to the cover factor or the production factor or both. Please revise the table to present the reference area and corresponding reclaimed area sample information in logical order. Further, please insert a column titled "Cover Success Demonstrated" within the "Absolute Cover" block of the table, and re-title the "Adequacy Demonstrated" column on the far right side of the table "Production Success Demonstrated". Please delete the confusing "adequacy demonstrated..." footnote. Table I was revised for the Aug. 2010 submittal. Item resolved. c) The Mean and 90% of Mean values listed in the Absolute Cover block of the table for various categories are erroneous; IP Reference Area 2007 values should be 75.2% and 67.7% respectively, DP Reference Area 2007 values should be 30.3% and 27.3% respectively, and IP Reference Area 2008 values should be 57.8% and. 52.0%, respectively. Please revise the table with the correct values. Table 1 was revised for the Aug. 2010 submittal. Item resolved. d) The next to last narrative paragraph on revised page 28 (beginning with "Irrigated Pasture cover in the reclaimed area...") is confusing and contains inaccuracies; it should be deleted. The specified paragraph was eliminated in the Aug. 2010 submittal. Item resolved. e) Inclusion of the final narrative paragraph on the page, the subsequent t-test, and related paragraphs on the following page is unnecessary, and merely repeats information that is adequately covered in Appendix B. A simpler approach would be to asterisk the "Yes" notation for the 2007 Dryland Pasture Reclaimed Area Cover, with a footnote to refer the reader to the West success demonstration in the applicable section of the Appendix B, BIO-Logic Phase 3 Vegetation Report (Section 3.3, pages 14-16). The entire narrative after the initial paragraph below Table 1 could be replaced with a statement referring the reader to the BIO-Logic, Inc. report in Appendix B, "2007-2008 Vegetation Studies for Phase 3 Bond Release... ", for a detailed presentation of data, sampling methods, statistical demonstrations of success, and summary discussion of study results. Please revise the narrative as appropriate. In the Aug. 2010 response, WFC clarified the reclamation success discussion, and refers the reader to Appendix B, page 10, for a detailed discussion of the comparison. Item resolved. In accordance with the bond release guideline (pages 11 and 12, Items 1 and 4), please provide a narrative summary of the reclamation and management history of the parcels included in the Phase III release request, including narrative regarding achievement of the approved post-mining land uses. In addition, please provide narrative addressing the "quality standard" of the approved permit for irrigated pasture (i.e. that "at least 75% of the relative production will be comprised of seeded species or species of comparable quality as livestock forage). Because production data was not collected by species, conformance with this requirement may need to be based in part on inference from the vegetation relative cover data. WFC's Aug. 2010 response described the reclamation history, but did not provide a description of the management history (grazing, irrigation methods and frequencies, harvesting, fertilizing, etc.). In response to the Division's reiteration of this item in its March 9, 2011 review letter, WF'C submitted the March 17, 2011 package, in which WFC talks generally about management activities prior to TR-58 and following TR- 58 approval. The management activities prior to TR-58 are very general, and do not satisfy the requirements approved in TR-58. WFC further discusses management after TR-58, again in very general