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Maybe I should ask the question another way. If the old RA is kept, how would the reclamation fail the <br />comparison? Perhaps I have the wrong impression, but I see the veg requirements as having three main <br />components: species diversity including cool and warm weather grasses, production, and cover. Which of these <br />would the old RA affect? Which would the new RA affect? <br />You say that the old RA has 0.2 acres that are not previously disturbed. That is an area of about 93' by 93' <br />which is not insignificant. How does the veg on this portion compare with the area you think is disturbed? <br />Has the veg on the proposed RA been sampled? <br />Doug <br />- -- On Thu, 5/31/12, George Patterson < eoal(a �. -mail com wrote: <br />From: George Patterson < efcoal gmail.com <br />Subject: Re: Fw: Re: Southfield vegetation comparisons <br />To: "W D Corley, Jr." < Ajc(a�att.net > <br />Date: Thursday, May 31, 2012, 11:21 AM <br />Doug, <br />I was tied upon work for EF's other mine. Old RA: The 'required' parameters for the reclaimed <br />ground of course don't change. The consultant tells us that the current (old) RA is too unlike, not <br />comparable to, the conditions that effect the parameters of the reclaimed ground and if comparisons <br />are made to the old RA, the reclamation requirements would probably not be met. We had wondered <br />about viability of the old RA but only recently did the consultant obtain more old photos showing more <br />predisturbance than suspected. And yes, the consultant claims the new, proposed RA is more <br />comparable to the reclaimed ground. <br />The consultant is generating a response to the Division, when we have a more finallized version I will <br />send you a copy w/ photos. <br />Thanks, <br />George P <br />On Thu, May 31, 2012 at 7:04 AM, W D Corley, Jr. < aiicgatt.net > wrote: <br />George, <br />Since we don't have the veg data or the permit veg requirements, and we don't have the old and the proposed <br />reference area locations (maps), I will have to make some assumptions. I assume that your portal <br />area reclamation does not meet a T test <br />comparison with the old RA. If it did meet the test you would not be spending the time and money to try to <br />switch. However, it does not seem scientifically valid to go out now near the end of the ten year period when <br />the reclamation results are known and then go out to find an area for a new RA that could meet the test. You <br />state that the reclamation requirement would remain the same, but wouldn't the new RA allow a lower <br />revegetation standard? <br />Doug <br />- -- On Mon, 5/28/12, W D Corley, Jr. < ajjcLa ` net wrote: <br />From: W D Corley, Jr. < aiicnatt.net > <br />