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standard is based upon "total herbaceous production" we intended on clipping all annuals, <br />biennials and noxious weeds during the production sampling, but none were encountered in the <br />production sampling effort. <br />For each area sampled, a minimum of 30 production transects were used for sample adequacy <br />calculations. Following clipping, the harvested plant materials were dried in a drying oven at 100 <br />degrees C for a period of 24 hours, or until a constant weight ( +/- 0.1 gram) was achieved.. <br />Shrub Density Starting at each of the transect used for the plant cover and production sampling, <br />the fifty -meter tape was laid out along a predetermined and randomly selected alignment. <br />Woody stem density was determined using the center of the tape as a modified belt transect. The <br />right -hand side of the transect was called Side A and the left -hand side of the tape was called <br />Side B. Data collected from each side were added into a transect value which represents the <br />number of shrubs sampled in the 100 m sample plot. These data are reported in the Results <br />Section as to the number of shrubs per 100 m as well as the number of shrubs per acre as <br />outlined in the Permit. The revegetation woody plant density success standard is 1,500 stems per <br />acre or 37.06 stems per 100 m for all reclaimed areas at the Marr Mine and Kerr Tipple areas. <br />Species Diversity. The plant cover data collected at each cover sample transect yielded data <br />relative to absolute and relative cover. These cover data were then converted into percent <br />composition or relative plant cover by species based upon the total amount of plant cover <br />encountered in each sample transect. The relative importance values of plants growing on the <br />reclaimed areas in terms of their value for grazing animals as explained and approved by the <br />CDRMS in TR -25, approved on July 13, 2012, contains standards relative to the forage quality <br />of the reclaimed areas located at the Marr Mine and Kerr Tipple for grazing animals. <br />As described in TR -25, which has been incorporated into the Kerr Permit document, the species <br />diversity standard for 2009, requires that at the Marr Mine site, the reclaimed plant community <br />shall be composed of species which yield a forage quality index value, as calculated from the <br />Alkali Sagebrush Reference Area which equals 193.34. Application of the calculated forage <br />quality index value from the Kerr Tipple Reference Area, as sampled in 2009, means that the <br />forage quality index on the Tipple Reclamation site must be equal to or greater than a value of <br />210.18. <br />Historical Data. To evaluate vegetation trends over time, we compared data previously <br />collected during the 1980 baseline period contained in the Kerr Permit as well as previously <br />collected revegetation monitoring data. The Kerr Permit data is referenced by the Permit table <br />number, while the data collected by Rocky Mountain Reclamation (RMR) in 1996 entitled "1996 <br />Vegetation Sampling for Interim Monitoring and Bond Release" is cited as the RMR 1996 data. <br />Revegetation monitoring data collected in 1999 by ESCO and entitled "Report of Findings - <br />Reclamation Monitoring - Kerr Mine - Jackson County, Colorado" was also compared to our <br />data. These data are referenced as the ESCO 1999 data. The revegetation monitoring data <br />collected by HVIE Environmental Consultants in 2005 on these same four areas, and found in the <br />previously submitted report entitled " Revegetation Monitoring Report for Reclaimed Areas <br />Sampled in 2005 on the Kerr Coal Company's Marr Mine" was also compared to the data <br />4 <br />