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Page 5 of 9 <br />5.) The applicant used several different identifiers to discuss specific parcels of land included in the SL14 <br />bond release application. Some parcels have multiple identifiers leading to unnecessary confusion. For <br />example, a 20.5 acres parcel identified as Area 5 on map R -1, is referred to in the text as area IP -3. The <br />applicant should be encouraged to use only one identifier when discussing bond release parcel/blocks in <br />the future. <br />Area 6; 1" Year Data Review: <br />For 2010, the first year of sampling data was reviewed for Area 6 even though the grazing practices are difficult <br />to compare for this year. Given the issues discussed for the 2011 data below, this area does not qualify for Phase <br />III bond release at this time. However, the review of the 2010 data for Area 6 identifies several deficiencies with <br />this revegetation monitoring report and discussion of these results in the SL14 application that could be improved <br />upon for future bond release applications and revegetation sampling efforts. <br />6.) The 2010 monitoring data provided the first year of monitoring for Area 6 necessary to demonstrate Phase <br />III bond release, the second year of sampling was conducted in 2011 and the Divisions review of that <br />sampling effort is discussed below. <br />Plant cover measurement methods were conducted in accordance with the rules and what is approved in <br />the permit. Production measurement methods were slightly different than what is approved in the permit. <br />Page 3 of the 2010 Revegetation monitoring report indicates that three 1/4 meter circular plots were <br />measured for each of the transects sampled. The permit indicates a single production plot will be <br />collected at the origin of a transect on the left side. The Division does not believe the sample method <br />actually utilized negatively impacted the data or varied beyond what is acceptable in the regulations. <br />Permit section 2.05.4(2)(e) subsection 4.5 indicates the vegetation sampling will be conducted late May to <br />early June but immediately prior to the 1 st hay harvest of the season. Vegetation sampling conducted for <br />the reference area and Area 6 was conducted on July 9th to the 14th of 2010, this is outside of the approved <br />timeframes for sampling but the report indicates sampling was conducted prior to cutting hay that season. <br />The management histories section of the SL14 bond release application discusses the management <br />histories for 2010 for the Irrigated Pasture Reclaimed areas and the Reference Area. For 2010, there are <br />some differences in management histories between the two sites. However, the sampling methods and <br />results were reviewed given the nature of the differences in management. In regards to irrigation; the <br />Reclaimed Area did not receive irrigation water until May 8th, 2010, the Reference Area received <br />irrigation water on April 19, 2010 putting the reclaimed area at a possible disadvantage at the time of <br />sampling. In regards to grazing, it is difficult to compare the grazing practices conducted on Area 6 and <br />the Reference Area. However, grazing of these two areas was only conducted in the fall of 2010 after the <br />parcels were sampled for revegetation success, thus grazing should not have impacted the sampling effort <br />and results. In regards to hay production, the Reclaimed Area was cut for hay but the Reference Area <br />does not appear to have been harvested in 2010. However, as indicated above, sampling was conducted <br />prior to the Reclaimed Area being cut for hay. The differences in management practices that were <br />conducted in these areas in 2010 either occurred after the parcels were sampled for revegetation success <br />or management activities likely put the Reclaimed Area at a disadvantage in comparison to the Reference <br />Area. <br />The relevant sections in the New Horizon Mine permit defining the revegetation success criteria for the <br />Irrigated Pasture Reclaimed areas can be found in section 2.05.4(2)(e) subsection 4.5.3. The permit <br />indicates that " Revegetation will be deemed adequate if vegetation cover and herbaceous production at <br />the reclaimed site is at least 90% of the vegetative cover at the reference area and herbaceous production <br />is at least 90% of the reference area standard, after the weighted average soil adjustment ". The 2010 <br />revegetation monitoring report provides summary tables and a discussion of the results of sampling both <br />