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Page 7 of 9 <br />The narrative provided in the Phase III bond release portion of the SL 14 application for the 2010 <br />revegetation monitoring results for production contains discrepancies in the reported production for the <br />Area 6 (IP -4) irrigated pasture reclaimed area. Similarly, the 2010 Revegetation monitoring report <br />narrative for the production results for Area 6 (IP -4) is inconsistent with the results tables provided in the <br />report. The Division was able to review and verify the applicant's data based on the tables provided in <br />the 2010 revegetation monitoring report. However, the discrepancies in the narratives in the SL14 <br />application and revegetation monitoring report causes one to question to integrity and validity of the data. <br />These types of errors should be at an absolute minimum for a bond release application. Table 2 of the <br />2010 revegetation monitoring report provides a statistical summary of the cover and production sampling <br />results for Area 6 and the Reference Area. Also included on this table are the results of the sample <br />adequacy calculations. <br />The applicant reports the total and average mean production associated with different plant life forms for <br />both the Reference Area and Area 6. Both the Reclaimed and Reference Area consisted of perennial <br />grasses, perennial forbs, annuals and noxious weeds. The applicant's consultant further subdivided some <br />of these life forms into seeded grasses and seeded forbs for the reclaimed area. Also, the applicant <br />created a category of non - seeded desirable perennial grasses and forbs. For both the Reclaimed and <br />Reference Area, the applicant found the total and mean production associated with "Desirable" and <br />"Undesirable" species. The 2010 revegetation monitoring report discusses how species were assigned to <br />these two categories. Essentially, seeded grass and forbs species and non - seeded grass and forb species <br />used for pasture and haylands with high to moderate ratings for palatability and forage quality for grazing <br />animals were considered "Desirable" species. Annual species and perennial forb /grass species that have <br />toxic or low palatability and forage quality for grazing animals were considered "Undesirable" species. <br />Quackgrass and Field Bindweed were designated as "Undesirable" species and were not utilized to derive <br />the success standard for production. Also, the production associated with Quackgrass and Field <br />Bindweed were considered "Undesirable" in the Area 6 data results and were not counted toward meeting <br />the success standard for production. <br />For the Irrigated Pasture Reference Area, mean desirable production was found to be 63.95 grams per 11/4 <br />meter'. The success standard is 90% of this mean desirable production after the weighted average soil <br />adjustment factor is applied as discussed in the permit. The 2010 revegetation monitoring report indicates <br />the weighted average soil adjustment factor for Area 6 is .728. Given this, the success standard for <br />production was calculated by taking the mean desirable production found on the reference area (63.95 <br />grams per 11/4 meter') and multiplying that by the weighted average soil adjustment factor (.728), and the <br />success standard is 90% of the final result. See calculation below: <br />63.95 X.728= 46.56 grams per 11/4 meter' <br />90% of 46.56 grams per 11/4 meter' = 41.90 grams per' /4 meter' <br />As indicated above, the applicant did not provide documentation or justification on how the .728 <br />weighted average soil adjustment factor was determined. They will need to provide this information in <br />order for the Division to accept the 41.90 grams per 11/4 meter' success standard for cover. However, <br />assuming this number is correct the Division used this result to judge revegetation success for production <br />of Area 6. <br />For Area 6, the applicant reported the mean desirable production was found to be 7333 grams per 11/4 <br />meter'. The applicant demonstrated Area 6 had been sampled an adequate number of times. Thus, the <br />mean desirable production found on Area 6 is greater than the success standard derived from the reference <br />area. However, the Reference Area samples did not meet the statistical adequacy requirements. Based on <br />the total average production measured in the reference area, the sample size requirement was found to be <br />