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Binns, Janet <br />From: George Patterson [efcoal@gmail.com] <br />Sent: Thursday, May 19, 2011 5:42 PM <br />To: Binns, Janet <br />Subject: Fwd: Proposed Species Diversity Standard for Kerr <br />Attachments: KERRSPECIESDIVSTD.doc <br />?2a? SC©w? C ?) SU - C)o (c DrG SAIA . <br />Janet, <br />Thank you for your voice message today! ! I should have followed up sooner - - Kent's email is dated March <br />31,'11. Kent had told me you were willing to look at his 'Draft' prior to submittal of the TR. I assumed you <br />were focusing your expertise on his draft. <br />Anyway, I am forwarding the copy I received, please let me know if you receive it OK. <br />Thanks again, <br />George P <br />---------- Forwarded message ---------- <br />From: Kent Crofts <kent(aOmeyampa.com> <br />Date: Thu, Mar 31, 2011 at 10:47 AM <br />Subject: Proposed Species Diversity Standard for Kerr <br />To: Janet.Binnsastate.co.us, George Patterson <efcoal g!nail.com>, Kent Crofts <kent@imeyampa.com> <br />Janet: <br />In accordance with the discussions we had in your office on January <br />24th I am forwarding you a proposed species diversity standard for <br />Kerr. Please be aware that analysis of the 2010 reference area data, <br />which we have just recently summarized also documents that the <br />undisturbed Tipple Reference Area would fail the currently approved <br />permit species diversity standard required for the Kerr Tipple <br />reclamation, just like the 1999 Reclamation did in the 2009 sampling <br />effort. <br />Please be aware that we pursued the issue of the Structural Diversity <br />Standard which we discussed in your office but after spending nearly <br />almost a day crunching the numbers, and after applying numerous <br />assumptions on the existing plant heights, which we did not measure we <br />can away after consulting numerous taxonomic manuals even more <br />confused than ever in how one comes up with an average plant height <br />which can be used to calculate the proposed structural diversity <br />index. Yes, in my opinion this is probably a doable option, but it <br />takes probably 4 or 5 times longer than does the old relative percent <br />plant cover approach. <br />What I finally decided to do was to do a careful evaluation of the RA <br />data and calculate values consistent with the two undisturbed that we <br />are using. The attached narrative explains the approach we used. What <br />is different about this approach than the approach used in the early