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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 <br />Page 20 <br />that the transect selection was unbiased" is totally inconsistent with numerous other <br />vegetation sampling efforts that have conducted and accepted by the DRMS using the <br />exact approach used herein by now having the DRMS require that documentation must <br />now be submitted documenting why this sampling approach is acceptable. <br />Our conclusion after careful examination of the DRMS comments along with numerous <br />statistical references, is that the vegetation sampling approach applied herein is more <br />unbiased and is more in harmony with the spirit and intent of the DRMS regulations and <br />Vegetation Guideline, than the method herein being suggested by the Division. <br />However, to clarify the exact transect sampling methodology used, clarification on the <br />manner in which the transects were actually sampled is presented beginning on revised <br />page 3 Exhibit 5. <br />Division Response: On page 4 -6 of Exhibit 5, the procedure for ensuring randomly located <br />sample locations is described. The sampling sequence in the pre - disturbance area is <br />sequential. Therefore, our assumption is that transects in the reference area would also be <br />sequential to maintain random selection. This was not the case for cover and woody plant <br />density sampling within the Greasewood Reference Area where transects 1 -24, 29, 33, 37, <br />39, 40, 42, 44, and 46 -50 were measured. By looking at these sampled transects, it appears <br />that sampling started out sequentially but became selective after #24, yet, in the <br />predisturbance areas, transects were sampled for cover and shrub density sequentially, 1 <br />through 25. The Division does accept "both random and systematic (selective) sampling <br />designs" as per Rule 4.15.11(1), but also requires "consistency in sampling." The <br />explanation given in the last adequacy response does not clarify the issue as to whether the <br />transect selection was unbiased. Please provide an explanation within the appropriate <br />section of Exhibit 5, explaining why cover data was collected sequentially in the <br />predisturbance area and sequentially /selectively in the reference area to meet sample <br />adequacy. <br />27a. The legal applicant for the Fruita Unit Train Loadout is CAM - Colorado LLC as <br />listed on page 2.03 -1. Rhino Energy is referred to in Exhibit 5 on Page 5 and tables <br />10 -31 10 -9 and 10 -10. Please amend the text to refer to CAM --- Colorado LLC for <br />clarity and to prevent confusion. <br />27b. The transect lines on Map 5 of Exhibit 5 are difficult to see. Please submit a new <br />version of Map 5 that has clearly visible transect lines against the background photo. <br />27c. Transect LGRRA -34 on Map 5 is not completely in the reference area. The east end <br />of the transect crosses the stream and continues into a riparian area. Is this accurate <br />or is it a mapping error? <br />27d. The column and/or row headings in tables 10- 4,10 -5, 10 -6 and 10 -13 were cut -off. <br />Please correct the tables so the headings are legible. <br />