2013-03-08_REVISION - C1981008 - Laserfiche WebLink

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Page 8 of 9 483 samples and only 30 plots were sampled in the field. Given this, the applicant used the reverse null hypothesis statistical approach allowed in Rule 4.15.11(2)(c) to demonstrate revegetation success for production on Area 6. Based on the data, the t,� value was found to be 3.191 by the applicant, based on the Division calculations, the t,� value was found to be 4.509. The tt value at an alpha error probability level of .2 was found to be 1.311. Given that t,� value is greater than tt using either t,� value, the null hypothesis is rejected and the mean desirable production statistically exceeds the success standard. Again, this determination is based on the assumption that the Operators weighted average soil adjustment factor is correct and would need to be verified. Part of the success standard for production is a quality standard, the permit indicates that 75% of the relative production found on a reclaimed irrigated pasture area will be comprised of seeded species or species of comparable quality as livestock forage. For Area 6, seeded grasses and forbs made up 37.73% and 50.23% respectively of the total production found in Area 6. The relative production percentage associated with seeded species is 87.96% which exceeds the 75% standard. Thus the quality of production of Area 6 is acceptable. 7.) For future bond release applications for Irrigated Pasture Reclaimed areas, the applicant will need to provide the Division details on how weighted average soil adjustment factor was determined. This information should include a table similar to Table 2.05.4(2)(e) -2 in the permit. The applicant will need to provide a map that delineates the proposed bond release reclamation block overlaying the designated soil types to demonstrate how the necessary acreages were found to generate the weighted average soil adjustment factor. 2011 Phase III Revegetation Monitoring Data Pages 47 and 48 of the Phase III portion of the SL14 application provide a summary of the 2011 sampling effort for two bond release blocks. The narrative is a summary of the "Revegetation Monitoring Report for Reclaimed Areas Sampled in 2011 on the Western Fuels — Colorado LLC — New Horizon NI-12 — Mine" dated 29 August 2011 and will be referred to in this review as the 2011 Revegetation Monitoring Report. The description of the bond release blocks on pages 47 and 48 of the SL 14 application and the 2011 Revegetation Monitoring Report are inconsistent and poorly identified. Map R -1 of the SL14 application identifies 6 parcels of land to be considered for final Phase III bond release; these areas are labeled Area 1 through 6. This map also identifies what years these parcels were sampled to ascertain revegetation success. According to Map R -1 in 2011, Area 6 was sampled to account for the second year of monitoring for this area. Areas 1, 2 and 3 were monitored to account for their first year of monitoring for Phase III bond release. Area 6 is a 44.1 acre parcel and Areas 1, 2 and 3 consist of 4.2, 26.9 and 95 acres respectively. The narrative on pages 47 and 48 of the application indicates a 44.1 acre parcel identified as "IP -4" and a 95 acre parcel identified as "IP -3 — Phase III" was sampled in 2011. The 2011 Revegetation Monitoring Report indicated two bond release blocks were sampled, a 95 acre parcel identified as "IP -4" and a 126.2 acres parcel identified as "IP Phase III or SL -12" area. The 2011 Revegetation Monitoring Report included three maps that supposedly indicate were sampling took place; Map 1 depicts the Irrigated Pasture Reference Area, Map 2 depicts a 44.1 acre parcel that appears to correspond to Area 6 on Map R -1 of the SL14 application, Map 3 depicts three parcels sampled that appears to correspond to Area 1, 2, and 3 depicted on Map R -1 of the SL14 application. The acreages and the identification of the bond release blocks sampled in the 2011 sampling effort are inconsistent and confusing. These issues call into question the integrity and validity of the 2011 sample effort. Several fundamental assumptions would have to be made on the part of the Division for the 2011 sample effort that the data collected corresponds to a certain bond release block. For a bond release application there should be no question on this subject. The Revegetation Monitoring Reports submitted with the SL14 application were created by consulting firms and should stand alone for the sampling efforts conducted. Edits and corrections to these reports should have been made long before they were submitted to the Division as justification for a bond release application. The integrity of these reports would be further in question if they were revised and re-