2011-05-17_REVISION - C1981008 (2)

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to the success standard is accepted. Thus, the reclaimed area vegetative cover may be deemed successful for the purposes of the law. The statistical test really should not be necessary. As pages M-120 through M-12R of the approved permit application state, the baseline data upon which the cover standard has an important deficiency. The shrub and herbaceous cover data were collected separately from each other allowing overlapping hits to count toward the absolute cover. Several of the transects from the original data had absolute cover values in excess of 100%. The equivalent way of sampling using an optical point frame would be to record second and third hits from species different from the first hit species as first hits. For instance, normally if the first hit was from a LECI individual and the second were from a BRIN individual, 2% of cover would be counted toward the transect value. However, in trying to replicate the baseline techniques, this single point would actually contribute 41/o cover to the final transect value because two different species were intercepted. If the 1996 sample data were recalculated this way, total perennial vegetative cover would increase to 60.7% and total cover would increase to 62.7%. Because 60.7% exceeds the 90% comparison value, no statistical comparison would have. even been necessary. Thus, using a sampling methodology equivalent to the baseline study, the reclaimed area data would definitely have been deemed successful without a statistical demonstration. Relative cover data is summarized in Tables 5 and 6. As was the case with the absolute cover data, the bulk of the vegetative hits is contributed by the twenty-four perennial, non-noxious species (96.9% of hits). Thirty-two species were encountered during sampling. On average, 5.9 species were encountered per 50 point transect, with an average of 5.4 being perennial and non-noxious. 8