2011-07-11_APPLICATION CORRESPONDENCE - C2010088

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Mike Boulay Rule 2.04.10 Vegetation Information 25. Division Response: Response accepted. 25a. Map 3, Permit Area Vegetation Map — The entire permit area is not included on the map. The borrow pit area on the south side of the permit boundary and the haul road have been cut off. Please submit a new map that includes the entire permit area including the entire haul road. CAM - Please see revised Map -03 26. Division Response: Response accepted. -11- July 8, 2011 27. On page 2 and 3 of Exhibit 5, the procedure for ensuring random location coordinates for each sample transect is described. Based on the approach described, our assumption is that transects would be numbered in accordance with the sequence selected, and, if 30 transects were run for a particular parameter within a delineated sampling unit, transects 1 through 30 would be sampled, to maintain the random selection. This was not the case for cover and woody plant density sampling within the Greasewood Reference Area, in which data was recorded for a total of 36 transects, including Transects 1 through 24, 29, 33, 37, 39, 40, 42, 44, and 46 through 50. Please provide an explanation for inclusion within the appropriate section of Exhibit 5, demonstrating that the transect selection process was unbiased, and explaining why cover data was not obtained from sequentially numbered transects to meet sample adequacy. CAM - A lengthy discussion was provided in the #1 adequacy letter that explained the transect selection process. Division Response: On page 4 -6 of Exhibit 5, the procedure for ensuring randomly located sample locations is described. The sampling sequence in the pre - disturbance area is sequential. Therefore, our assumption is that transects in the reference area would also be sequential to maintain random selection. This was not the case for cover and woody plant density sampling within the Greasewood Reference Area where transects 1 -24, 29, 33, 37, 39, 40, 42, 44, and 46 -50 were measured. By looking at these sampled transects, it appears that sampling started out sequentially but became selective after #24, yet, in the predisturbance areas, transects were sampled for cover and shrub density sequentially, 1 through 25. The Division does accept "both random and systematic (selective) sampling designs" as per Rule 4.15.11(1), but also requires "consistency in sampling." The explanation given in the last adequacy response does not clarify the issue as to whether the transect selection was unbiased. Please provide an explanation within the appropriate section of Exhibit 5, explaining why cover data was collected sequentially in the predisturbance area and sequentially /selectively in the reference area to meet sample adequacy.