2011-06-02_APPLICATION CORRESPONDENCE - C2010089 ‎(12)‎

• Permit No: C2010089
• IBM Index Class Name: Application Correspondence
• Doc Date: 6/2/2011
• Doc Name: Vegetation Survey
• Section_Exhibit Name: Section 2.04.10
• Email Name: MLT
• Media Type: D
• Archive: No

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As described in Permit Section 2.05.4(2)(e) Revegetation, the species diversity standard being
proposed for the various reclaimed plant communities at the NHN Mine are the same as
currently approved for the NH2 Mine. The proposed standards for species diversity to be used at
the time of final reclamation for the NHN Mine are found in that section.
Statistical Analysis of Data. As required by the Division's regulations and associated policies,
it is not necessary to achieve sample adequacy for vegetation monitoring provided that at least
fifty transects have been sampled. As required in Section 4.15.10, a minimum of 15 cover
transects and 30 production transects were collected from each vegetation type sampled. As
outlined on page 15 of the Vegetation Guideline, during a permit consultation meeting, Ms.
Sandy Brown and Mr. Dan Mathews, gave verbal approval for WFC to cease sampling after fifty
production transects had been collected was given. Therefore, all of the data collected in this
evaluation were analyzed for sample adequacy in order to determine whether the Division's
requirements for sample size had been satisfied.
The existing DRMS regulations require that shrub density be sampled to sample adequacy and
that a minimum of at least 30 shrub density transects be sampled on each site. However, on 30
July 2006, OSM issued revised regulations regarding the issue of shrub density revegetation
success standards, eliminating the need to sample shrub density. Thus, the requirement to
sample shrub density has been deleted on the federal level and the DRMS has applied to change
their regulation accordingly, but to date, no approval has been issued for this requested change in
the state program. Given this regulatory contradiction, during permit consultation meetings, Ms.
Sandy Brown and Mr. Dan Mathews directed WFC to sample only 15 transects for shrub density
and said that it was not necessary to achieve sample adequacy for this parameter. The sample
adequacy formula contained in the regulations was used, wherein a precision of 0.10 was used
for cover and production and 0.15 for shrub density.
On all of the proposed mine disturbance areas and reference areas sampled, all of the field data
were analyzed in terms of "total plant cover" to determine whether sample adequacy was
achieved prior to leaving the site being sampled. On all areas sampled for production, a
minimum of 30 samples were collected and the green plant weight data analyzed to determine
whether sample adequacy had been achieved. On all sites sampled for shrub density, a minimum
of 15 samples were collected and the data analyzed to determine whether sample adequacy had
been achieved. In instances where production was not achieved with 30 samples, then a
maximum of 50 transects were sampled.
During the consultation meetings held with the DRMS, WFC was informed that if was not
necessary to submit copies of the raw field data sheets, but that this information should be kept in
our files in the event that the DRMS determined that they needed to review this information.
(Kent — submit a copy of raw data to WFC)
Section 2.04.10 Page 5 April 2011