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June 28, 2013 2010 sampling summary and weighted average examples <br />If we calculate the same example using the 1980 Plot B data: <br />0.90[(0.798 x 1000) +(0.202 x 500) <br />_ .90[(798) + (101)] <br />=899 Ibs /acre herbaceous production <br />In this instance, using the estimated 1980 statement from D. Loukonen of 500 Ibs /acre, the old Plot B <br />indicates that the proposed reference area might result in a slightly lower productivity standard. However, <br />since we do not have actual productivty data from 1980, but only SCS (NRCS) recommended range <br />productivty, the productivity success criteria would vary when based on updated reference area sampling. <br />Once again, the 2010 herbaceous productivity on the reclaimed Vento property would still exceed the <br />weighted average comparison. <br />Woody stem comparison: <br />The 1980 pre - permit data did not collect woody stem data in the same manner as the approved <br />method in the permit. Instead of counting trees and shrubs as woody stems per unit area, the 1980 data <br />collected shrubs as a percent cover value and then trees (greater than 1.35M high) by number of trees <br />per acre. The currently approved woody stem density standard on the Vento property is based on <br />counting shrub and tree species in a unit area, stems /acre. There is no required woody stem density <br />requirement on the reclaimed Corley property. <br />0.90[(0.798 x 3.8) +(0.202 x 6375) <br />_ .90[(3.03) + (1287.8)] <br />= 1,161.7 woody stems per acre <br />Using the proposed PJ reference area 2010 woody stem per acre count of 6375 stems /acre and the 1980 <br />Plot A trees per acre value of 3.8 trees /acre, the minimum woody stems per acre that the operator would <br />need to meet at Phase III bond release would be 1,161.7 stems per acre. This is an example only. <br />If we do the same calculation using the 1980 data from Exhibit 11 of the permit: <br />0.90[(0.798 x 3.8) +(0.202 x 25) <br />_ .90[(3.03) + (5.05)] <br />=7.27 woody stems per acre <br />This is not a true representation since the 1980 data did not sample shub species as woody stems per <br />unit area and only reflects tree species. <br />A change to either reference area would have no effect on the diversity standard as the standard is <br />defined in the permit and not based on comparison to a reference area. <br />To reiterate, the examples here are only to show how the wieghted average success criteria <br />would be applied at the time the operator applies for bond release. These example do not imply <br />that these values are the actual success criteria values that will be used at the time the operator <br />conducts success sampling in compliance with the approved permit. <br />