2012-06-20_PERMIT FILE - C2010089A (7)

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cover. For example, if there are two herbaceous species encountered in the sampling of the Dryland Pasture Reference Area that possess total relative cover values of greater than five percent at the time of final bond release sampling then the species diversity on the reclaimed Dryland Pasture areas would require that there be at least two species encountered in the sampling of the Dryland Reclaimed Areas. With respect to a maximum species diversity standard, the maximum total relative plant cover on the Dryland Reclamation will be less than the maximum total percent relative cover encountered in the sampling of the Dryland Pasture Reference Area. For example, if the maximum total percent relative cover encountered for any single species in the sampling of the Dryland Pasture Reference Area is 60 percent, then the maximum allowable total relative cover for a single plant species on the reclaimed area could not exceed 60 percent. 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. Section 2.04.10 Page 5 November 2011