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Results of vegetation sampling indicated that all of BRB -3 and BRB -4 and the two reference <br />areas exceeded the first -hit herbaceous cover standard. The BRB sampling at thirty locations <br />resulted in cover data that exceeded 90% of the cover standard of 36.2% allowable cover. <br />The figure for allowable cover in the BRB of 40.0% is the result of subtracting tree, shrub <br />and non - herbaceous cover, perennial noxious weed cover, and excess annual /biannual cover <br />from the observed first -hit total vegetation cover of 44.7 %. <br />Although the allowable first -hit herbaceous cover sample adequacy was achieved for the <br />BRB's and the sage brush reference area, the sample adequacy using the allowable first -hit <br />cover was not met at the mountain brush reference area. The lack of sample adequacy for the <br />mountain brush reference area necessitated utilizing an alternative approach to achieve <br />adequacy. In the development of the alternative approach, it was determined that the true <br />mean (within 90% confidence) for the mountain brush reference area lies between 10.48 and <br />15.12 percent cover. The highest possible value with 90% confidence of 15.1% cover was <br />utilized as the allowable herbaceous first hit cover in the mountain brush reference area. The <br />Division determined that the alternative approach meets or exceeds the standard set by the <br />historic methods used to determine sampling adequacy for the mountain brush reference area. <br />Although vegetation species diversity is not a criterion for Phase II bond release, the Division <br />evaluates cover data at Phase II to ascertain if the reclamation is approaching the diversity <br />success criteria. SCC's species diversity standards for rangeland /wildlife habitat areas <br />consist of using the following four tests, with success demonstrated by passing the first (A) <br />and at least two of the remaining three (B, C, and D): <br />1) Mandatory test: No Overwhelming Dominant Species — No single species may <br />exceed 60% relative cover. <br />2) Alternative test: Total Species Density — The total mean species density in the <br />reclaimed area equals or exceeds the central 75% of the distribution of the area <br />weighted overall species density determined from cover sampling. <br />3) Alternative test: Distribution of Species Density in Comparison to the Reference <br />Area — Utilization of the Motyka similarity index to assess resemblance of the <br />distribution of species. <br />4) Alternative test: Assessment of the Presence of Native Species — Comparison of <br />number of native species in the sample area to the referenced area. <br />(Permit Appendix 13 -13) <br />Cover data show that based on meeting mandatory Test A and both Test C and Test D <br />alternative tests of species diversity, BBB's -3 and 4 would likely achieve the diversity <br />standards. <br />The high vegetative diversity observed during the June 12, 2011 bond release inspection <br />supports the data submitted with the bond release application. It appeared during the bond <br />release inspection that the BBB's displayed a lower cover, with a higher component of native <br />species and somewhat higher over -all diversity as compared to previously released BBB's. <br />This can be attributed to the later seeding and any interseeding completed. <br />Seneca II Mine Page 9 September 10, 2012 <br />Phase 11 Bond Release <br />