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A determination of species diversity will be evaluated using data collected from the cover data <br />sampling data of the reclaimed area. The Permit requires that "species diversity shall be <br />considered adequate when the four (4) dominant species, based upon plant cover, comprise no <br />more than 80 % of the total species composition. The two dominant warm season grass species <br />shall collectively comprise at least 50 % of the total plant cover." <br />Timin . The Southfield Mine Permit does not address the time of the vegetation sampling <br />effort. Therefore the recommendations found in the Vegetation Guideline which states on page <br />5 that the revegetation monitoring should correspond with the period of "peak production of the <br />dominant species. As a practical manner, sampling in most areas can be conducted from July <br />through September." Given the fact that this Permit emphasizes the importance of warm season <br />plants in the revegetation success criteria, sampling will be done toward the middle or end of this <br />sampling period. Sampling will commence on the refuse pile reclamation and reference area and <br />will commence on the portal reclaimed areas, thereafter. The Portal reference area will not be <br />sampled until approval is obtained from the CDRMS. <br />Transect Locations. Each vegetation transect will be located in the office prior to going to the <br />field using a random coordinate generating system. At each transect starting point, the <br />orientation or bearing of the transect will be randomized, based upon selecting a random number <br />between zero and 360 degrees. <br />PROPOSED VEGETATION SAMPLING METHODS. <br />Plant Cover. According to Permit Page 2.05.4 -26, plant cover will be measured utilizing "total <br />herbaceous vegetative cover" which will be measured by a "point intercept method." with <br />transects typically being 50 meters in length. However, the approved Permit also states that <br />"vegetation monitoring will involve the use of similar methods to those utilized in the collection <br />of the vegetation baseline data ... " Examination of the Baseline Vegetation Study found in <br />Exhibit 11 Vegetation Inventory of the Permit reveals that the length of the cover transect line <br />was 230 cm. The CDRMS has required in other revegetation sampling efforts involving <br />significantly larger reference areas, that transect lengths of 5 or 10 meters, rather than the typical <br />50 meter transect length must be used. Since the Permit so clearly states that the reclamation <br />monitoring effort "will involve the use of similar methods to those utilized in the collection of <br />the vegetative baseline data" EFCI has the understanding that use of transect lengths less than 50 <br />meters in length are already approved. <br />A minimum of at least 100 data points will be collected along each cover transect. Data will be <br />collected as first hits. , with each point be recorded as to the plant species present, whether there <br />is litter, bare ground or rock present. The 100 data points will be summarized into a single <br />datum for purposes of producing a transect cover value. Along each cover transect a total of 10 <br />randomly generated intervals will be calculated in the office prior to going to the field and will <br />be used to measure plant cover. At each random interval along the tape, a total of ten <br />observations will be collected. On the reclaimed areas, a 50 meter transect length will typically <br />be used and on the smaller reference area a 5 or 10 -meter transect length will be used. A 5 meter <br />transect length is consistent for cover sampling at Rule 4.15.10(1)(a)(ii) and woody plant density <br />sample at Rule 4.15.10(1)(c)(I) <br />Herbaceous Production. The regulations at Rule 4.15.10(1)(b)(I) require that the "current <br />annual growth of herbaceous, non - woody, species" be clipped on each production plot. <br />According to Permit Page 2.05.4 -27, herbaceous production will be obtained wherein "all plant <br />species will be clipped." Therefore, at each clip plot, the vegetation will be clipped by general <br />plant life form categories, including perennial grasses, perennial forbs, annual grasses and annual <br />