Attachment_1-_Performance_Work_Statement.pdf

PERFORMANCE WORK STATEMENT (PWS)

Wildland Urban Interface (WUI) Fuel Reduction Mastication on Ocean Springs Unit Mississippi

Sandhill Crane National Wildlife Refuge

Part 1

General Information

1. GENERAL: This is a non-personnel services contract to provide Wildland Urban Interface (WUI) Fuel Reduction Mastication on the Ocean Springs Unit of the Mississippi Sandhill Crane National Wildlife Refuge (MSCNWR). The Government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the Contractor who, in turn is responsible to the Government.

1.1 Description of Services/Introduction: The contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to perform Wildland Urban Interface (WUI) Fuel Reduction Mastication on the Ocean Springs Unit MSCNWR as defined in this Performance Work Statement except for those items specified as government furnished property and services. The contractor shall perform to the standards in this contract.

1.2 Background: The mission of the US Fish and Wildlife Service (USFWS) is working with others to conserve, protect and enhance, fish, wildlife, plants and their habitats for the continuing benefit of the American people. An important part of this is protecting the public from wildland fires. Refuges employ a variety of management techniques to reduce fuels; one priority method is through fuels reduction prescribed burning; alternative methods are through the use of mechanical and hand treatments. Refuges prioritize treatments based upon the management objectives and public safety; that is, the ability to meet the objectives of the refuge while keeping the public safe at the same time. This project will reduce and reorganize WUI vegetation (wildland fire fuels) through mechanical means to reduce the potential for large and damaging wildfire.

1.3 Objectives:

The area to be treated under this contract (treatment area) is 60 linear miles or 288 acres.

Final treatment area size and exact location (boundaries) are dependent upon the per acre price bid and total funding available. Treatment area may be prioritized within the project footprint within the 288 acres identified at the Ocean Springs Unit of MSCNWR. The project area will include the outside/exterior and interior perimeter of the existing firelines, specifically addressing overhang and heavy areas of vegetation impacting the firelines. Firelines consist of a combination of dirt fire breaks and graveled roads ranging in widths of 15 to 60 foot.

The project map attached identifies the project area. Project depth will be fluid due to private ownership and highway proximity of firelines. A general depth of treatment is 20 foot either side of existing firelines.

However, fuels on the interior side or within the burn units are generally lighter and will require little to no treatment. If no treatment is identified by the COR/Government Representative, then the acreage will be adjusted to either extend the depth on the adjacent side or increase depth within an identified area within the project to buffer a higher priority urban site from potential fire spread.

Within the treatment area, the contractor will use forestry mulcher or masticator equipment to shred, grind, mow, masticate or otherwise physically reduce and reorient the encroaching brush, trees, and downed, course woody debris into small residues that are in contact with the forest floor.

Within the treatment area, all brush, shrubs, saplings, and trees up to 6 inches diameter at breast height (DBH) will be masticated except for designated leave trees and riparian zones. Designated leave trees such as buffer zones and wetland areas could be excluded from the mastication to secure the protection of wildlife associated with the location of hazards associated with urban interface such as powerlines and sensitive soils of riparian zones.

Trees larger than 6 inch DBH will be left intact and undamaged. The COR and Government Representative will direct leave and take trees within the project area and will closely monitor and identify depths of treatment especially in areas that involve private landownerships. The COR/Government Representative reserves the right to determine priority treatment areas and move operations throughout the project area.

Residues from the mastication will be left onsite.

Residues from mastication will be small enough they do not pose a danger to personnel or light equipment working within the treatment area.

Greater than 80% of all residue pieces will be less than 2 feet in length and less than 2 inches in diameter.

There is no minimum size limit for residues, chips or shavings are acceptable and preferred.

Residues will be left so that the majority of them are in contact with the soil surface to promote decomposition.

Stumps from masticated trees, saplings and brush will be taken down to ground level / mineral soil.

The contractor must have GPS capability to locate and follow treatment boundary. A shapefile and / or georeferenced map will be provided to the contractor for navigation and location of treatment area.

The contractor shall provide USFWS GPS track files for navigating to the treatment areas.

Due to endangered species presence within this project area, coordination of all equipment or any operations will be critical to minimize disturbance to crane pre-release acclimation in November. As well as coordination during nesting season to avoid disturbance to nesting cranes. The COR and/or Government Representative reserves the right to stop all operations during these critical time frames.

1.4 Scope: Services include supplying, operating, and maintaining forestry mulching / masticating equipment to mechanically reduce wildland fuels/vegetation up to 288 acres within the Ocean Springs Unit at MSCNWR. The project area will be treated with a heavy-duty forestry mulching or brush cutting machinery that chips / mulches trees and brush. The equipment will be tracked or rubber tired with sufficiently low ground pressure to minimize rutting, soil compaction and residual tree root damage with maneuverable capabilities. Rutting greater than 6-inch depth is prohibited. Rotary drum masticating heads that are capable of being raised and lowered is required. The width of the cutting heads must be equal to, or greater than the width of the carrier, so that all vegetation within the path of the machinery will be masticated. Equipment of 100 horse-power or greater is recommended. The machinery must be capable of felling and masticating within dense stands of trees up to 6 inches DBH. It is also recommended that equipment has the capability to maneuver within in tight workspaces due to private landownership that borders the refuge boundaries.

The contractor will mulch all identified brush, saplings, and trees up to 6 inches DBH in the designated project areas. Residues from the mulching may be left onsite and evenly distributed across the treatment area. All downed vegetation will be mulched so that no portion of the residues lie greater than 6 inches above the forest floor. More than one pass with machinery may be necessary. All stems must be completely severed from the stumps and all residues must lie within a depth not greater than 6 inches from of the soil surface.

Within the treatment area, all downed, coarse woody debris lying on the forest floor up to 8 inches diameter will be masticated. This will include debris that was present before the contract period started and which was a result of natural forest process such as trees dying, limbs that have fallen from trees and logging slash or debris generated from other previous management activities.

Stumps from the treated vegetation will be reduced to the ground line and be level with the soil surface.

The majority of vegetative material or wildland fuel loading (fuels) within the treatment area, on average could be considered “heavy”. A small percentage of the fuels within the treatment area could be considered “moderate” and a small percentage of the fuels within the treatment area could be considered “light”. Prospective contractors are encouraged to conduct a site visit prior to bidding to form their own assessment as to the level of fuel / vegetation loading and resulting work and conditions that affect cost of performance required to masticate these wildland fuels within the treatment area. It is impractical to determine by other means the exact nature of work and the work site conditions under which the contract will be executed. The submission of a bid is considered certification that the site has been inspected and nature of work has been determined. Site visits and / or tours can be scheduled by calling the COR/Government Representative prior to submitting bid.

The treatment area may pass through or near year-round wet areas, ponds, areas of dense stems greater than 6 inches DBH or other features that prevent access with machine or mastication of wildland fuels / vegetation within. Accommodations may be made for the contractor to treat similar number of acres outside these specific areas or skip past inaccessible areas with no negative reflection on performance quality. In situations where the treatment area runs through course wood debris that is greater than the maximum diameter specified for treatment of 8 inches total diameter, such as a log, the contractor can masticate wildland fuels going up to and around that log, then skip over that specific log or large piece of debris.

All off-road equipment used for this contract shall be inspected by the COR, Government Representative or designee for the presence of invasive weed seeds or propagates prior to being off loaded at the Refuge.

Off-road equipment includes all equipment and any support off-highway utility vehicles, including service trucks, pickup trucks, and over the road transport trucks etc. All trucks, support vehicles, and equipment shall be cleaned with a pressure washer prior to arriving at the Refuge to remove all soil, plant parts, seeds, vegetative matter, or other debris which could hold seeds. The visual inspection will be conducted by the COR, Government Representative, or designee and will focus on, but not be limited to air breathers, tracks or tires, frame openings, floor plates, skid plates or other areas that can trap seeds. If seeds, clumps of soil or propagates are found the equipment will not be off-loaded and the contractor will be required to remove the equipment from the Refuge and wash it before engaging in contract implementation.

All work is subject to inspection by the COR, Government Representative, or designee during and after the Contractors operation. Unsatisfactory work shall be corrected promptly at no expense to the government.

The final size and shape of the treatment area is dependent upon the per acre bid rate submitted by the prospective contractor and the total funding amount available. The treatment area will consist of up to 288 acres. It is possible that individual sub-units or individual areas to be treated will be spread across the 288 acre project area within the Ocean Springs Unit. These individual sub-treatment areas will be determined by the COR or Government Representative. The contractor will be directed and moved from sub-treatment area to sub-treatment area at the COR or Government Representatives discretion.

1.5 Period of Performance: The period of performance shall be for one (1) Base Year of 12 months

(2025) and one (1) 12-month option year. The Period of Performance reads as follows:

Base Year – See attached map: Ocean Springs Firelines FY25 Mastication Area

Option Year I – See attached map: Ocean Springs Firelines FY26 Mastication Area (option). Option year will be implemented as funding allows and will include areas that were not completed in FY25.

The base period of performance will begin on September 1, 2025 and end on September 1, 2026.

Work may be postponed by the Government, due to inclement weather, high water levels, endangered species nesting periods, high wildfire danger or to prevent adverse impacts to the soils and access roads or for the convenience to the Government. The Government may allow an extension of the contract term if it is determined that the contractor could not complete the contract within the normal contract period due to excessive inclement weather or government caused delays that exceed a total of 14 days. The preferred time for completing the contract work is summer to early fall due to wet soil conditions associated with winter and spring rainy season.

1.6 General Information

1.6.1 Quality Control: The contractor shall develop and maintain an effective quality control program to ensure services are performed in accordance with this PWS. The contractor shall develop and implement procedures to identify, prevent, and ensure non-recurrence of defective services. The contractor’s quality control program is the means by which they assure their work complies with the requirement of the contract.

1.6.2 Quality Assurance: The government shall evaluate the contractor’s performance under this contract in accordance with the Quality Assurance Surveillance Plan. This plan is primarily focused on what the Government must do to ensure that the contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance, and the minimum acceptable defect rate(s).

1.6.3 Recognized Holidays: The Contractor may, but is not required to perform services on these holidays:

New Year’s Day Labor Day Martin Luther King Jr.’s Birthday Columbus Day President’s Day Veteran’s Day Memorial Day Juneteenth Day Thanksgiving Day Independence Day Christmas Day

1.6.4 Hours of Operation: Mulching / mastication operations should take place during daylight hours. The contractor and the COR, or Government Representative will coordinate times of scheduled work.

1.6.5 Place of Performance: The work to be performed under this contract will be performed at the Ocean Springs Unit of Mississippi Sandhill Crane National Wildlife Refuge.

1.6.6 Type of Contract: The government will award a firm fixed.

1.6.7 Security Requirements: Not applicable, no security requirements necessary. MSCNWR is a closed refuge except for the CL Dees Trail. No access provided to the public except at designated visitor use sites.

The contractor will be required to make arrangements with / notify the USFWS COR or Government Representative, Sami Gray at sami_gray@fws.gov or (228) 217-3256 of all work days.

1.6.7.1 PHYSICAL Security: The contractor shall be responsible for safeguarding all contractor equipment and property owned by the contractor. No government owned equipment will be utilized by the contractor. The Government will not provide any security for contractor owned equipment.

1.6.7.2 Key Control: The contractor will be provided a gate key for their own ingress and egress to the worksite to complete contract obligations. The key will be issued with the special use permit and must be returned to the USFWS Government Representative upon completion of the project or when the COR or Government Representative suspends operations.

mailto:sami_gray@fws.gov

1.6.7.3 Lock Combinations: The Contractor shall establish and implement methods of ensuring that all refuge gate locks with key are not revealed to unauthorized persons. The Contractor shall ensure that no duplicates of the key are manufactured and contract personnel having access to the project site safe guard against unauthorized entry.

1.6.8 Special Qualifications: The Contractor shall, without additional expense to the Service, be responsible for obtaining any licenses and permits, and for complying with any applicable State and Federal laws, codes, and regulations in connection with the performance of the work.

1.6.9 Post Award Conference/Periodic Progress Meetings: The Contractor agrees to attend any post award conference convened by the contracting activity or contract administration office in accordance with Federal Acquisition Regulation Subpart 42.5. The contracting officer, Contracting Officers Representative (COR), and other Government personnel, as appropriate, may meet periodically with the contractor to review the contractor's performance. At these meetings the contracting officer will apprise the contractor of how the government views the contractor's performance and the contractor will apprise the Government of problems, if any, being experienced. Appropriate action shall be taken to resolve outstanding issues.

These meetings shall be at no additional cost to the government.

1.6.10 Contracting Officer Representative (COR): The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and assists in contract administration The COR is authorized to perform the following functions: assure that the Contractor performs the technical requirements of the contract: perform inspections necessary in connection with contract performance:

maintain written and oral communications with the Contractor concerning technical aspects of the contract:

issue written interpretations of technical requirements, including Government drawings, designs, specifications: monitor Contractor's performance and notifies both the Contracting Officer and Contractor of any deficiencies; coordinate availability of government furnished property, and provide site entry of Contractor personnel. A letter of designation issued to the COR, a copy of which is sent to the Contractor, states the responsibilities and limitations of the COR, especially with regard to changes in cost or price, estimates or changes in delivery dates. The COR is not authorized to change any of the terms and conditions of the resulting order.

1.6.11 Key Personnel: The following personnel (UPON AWARD OF CONTRACT) are considered key personnel by the government: Sami Gray 228-217-3256 and/or David Stoesz 228-281-0290. The contractor shall provide a contract manager who shall be responsible for the performance of the work. The name of this person and an alternate who shall act for the contractor when the manager is absent shall be designated in writing to the contracting officer. The contract manager or alternate shall have full authority to act for the contractor on all contract matters relating to daily operation of this contract. The contract manager or alternate shall be available while work is being performed, Monday thru Friday except Federal holidays or when the government facility is closed for administrative reasons.

1.6.12 Identification of Contractor Employees: All contract personnel attending meetings, answering Government telephones, and working in other situations where their contractor status is not obvious to third parties are required to identify themselves as such to avoid creating an impression in the minds of members of the public that they are Government officials. They must also ensure that all documents or reports produced by contractors are suitably marked as contractor products or that contractor participation is appropriately disclosed.

1.6.13 Contractor Travel: Not Applicable

1.6.14 Other Direct Costs: Not Applicable

1.6.15 Data Rights: Not Applicable

1.6.16 Organizational Conflict of Interest: Not Applicable

1.6.17 PHASE IN /PHASE OUT PERIOD: Not Applicable

PART 2

DEFINITIONS & ACRONYMS

2. DEFINITIONS AND ACRONYMS:

2.1. DEFINITIONS:

2.1.1. CONTRACTOR. A supplier or vendor awarded a contract to provide specific supplies or service to the government. The term used in this contract refers to the prime.

2.1.2. CONTRACTING OFFICER. A person with authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the government. Note: The only individual who can legally bind the government.

2.1.3. CONTRACTING OFFICER'S REPRESENTATIVE (COR). An employee of the U.S. Government appointed by the contracting officer to administer the contract. Such appointment shall be in writing and shall state the scope of authority and limitations. This individual has authority to provide technical direction to the Contractor as long as that direction is within the scope of the contract, does not constitute a change, and has no funding implications. This individual does NOT have authority to change the terms and conditions of the contract.

2.1.4. DEFECTIVE SERVICE. A service output that does not meet the standard of performance associated with the Performance Work Statement.

2.1.5. DELIVERABLE. Anything that can be physically delivered, but may include non-manufactured things such as meeting minutes or reports.

2.1.6. KEY PERSONNEL. Contractor personnel that are evaluated in a source selection process and that may be required to be used in the performance of a contract by the Key Personnel listed in the PWS. When key personnel are used as an evaluation factor in best value procurement, an offer can be rejected if it does not have a firm commitment from the persons that are listed in the proposal.

2.1.7. PHYSICAL SECURITY. Actions that prevent the loss or damage of Government property.

2.1.8. QUALITY ASSURANCE. The government procedures to verify that services being performed by the Contractor are performed according to acceptable standards.

2.1.9. QUALITY ASSURANCE Surveillance Plan (QASP). An organized written document specifying the surveillance methodology to be used for surveillance of contractor performance.

2.1.10. QUALITY CONTROL. All necessary measures taken by the Contractor to assure that the quality of an end product or service shall meet contract requirements.

2.1.11. SUBCONTRACTOR. One that enters into a contract with a prime contractor. The Government does not have privity of contract with the subcontractor.

2.1.12. WORK DAY. The number of hours per day the Contractor provides services in accordance with the contract.

2.1.12. WORK WEEK. Monday through Friday, unless specified otherwise.

2.2. ACRONYMS:

ACOR Alternate Contracting Officer's Representative AFARS Army Federal Acquisition Regulation Supplement AR Army Regulation

CCE Contracting Center of Excellence CFR Code of Federal Regulations CONUS Continental United States (excludes Alaska and Hawaii) COR Contracting Officer Representative COTR Contracting Officer's Technical Representative COTS Commercial-Off-the-Shelf DA Department of the Army DD250 Department of Defense Form 250 (Receiving Report) DD254 Department of Defense Contract Security Requirement List DFARS Defense Federal Acquisition Regulation Supplement DMDC Defense Manpower Data Center DOD Department of Defense FAR Federal Acquisition Regulation HIPAA Health Insurance Portability and Accountability Act of 1996 KO Contracting Officer OCI Organizational Conflict of Interest OCONUS Outside Continental United States (includes Alaska and Hawaii) ODC Other Direct Costs PIPO Phase In/Phase Out POC Point of Contact PRS Performance Requirements Summary PWS Performance Work Statement QA Quality Assurance QAP Quality Assurance Program QASP Quality Assurance Surveillance Plan QC Quality Control QCP Quality Control Program TE Technical Exhibit

PART 3

GOVERNMENT FURNISHED PROPERTY, EQUIPMENT, AND SERVICES

3. GOVERNMENT FURNISHED ITEMS AND SERVICES:

3.1. Services: The Government will provide paper and / or digital, georeferenced map and GIS shapefile of treatment area. The Government, upon specific request from the contractor will delineate the treatment area boundary with timber marking paint or flagging. The Government will provide access to the treatment area.

3.2 Facilities: Not Applicable

3.3 Utilities: Not Applicable

3.4 Equipment: Not Applicable

3.5 Materials: Not Applicable

PART 4

CONTRACTOR FURNISHED ITEMS AND SERVICES

4. CONTRACTOR FURNISHED ITEMS AND RESPONSIBILITIES:

4.1 General: The Contractor shall furnish all supplies, equipment, facilities and services required to perform work under this contract that are not listed under Section 3 of this PWS.

4.2 Secret Facility Clearance: Not Applicable

4.3. Materials: The Contractor shall furnish all supplies, equipment, facilities, and services required to perform work under this contract that are not listed under Part 3 of this PWS including but not limited to fuel, fluids, maintenance, and repair items required to operate equipment required to conduct mastication within the identified treatment area.

4.4. Equipment: The contractor will provide heavy-duty forestry masticator machinery with rotary drumhead that can be raised and lowered with maneuverability. The equipment is recommended to have a minimum 100 horsepower and be of sufficiently low ground pressure as to minimize rutting, soil compaction or tree root damage.

PART 5

SPECIFIC TASKS

5. Specific Tasks:

5.1. Basic Services. The contractor shall provide forestry mulching / mastication services to mechanically reduce (grind / shred / chip) forest vegetation and wildland fuels on approximately 288 acres. Within the identified treatment area, all live and dead standing vegetation up to 6 inches DBH, and vegetation horizontal up to 8” total diameter will be treated. Residues generated from mechanical treatment will be distributed on the ground in and around the treatment area. Most of the individual pieces of masticated material (greater than 80% of total volume) will be less than 2 feet in length and less than 2 inches in diameter. Stumps from standing vegetation will be masticated to a height level with the soil surface.

Individual pieces or piles of mastication residues will be left, not to exceed a height of 6 inches from soil surface (no piles, limbs or stack of sticks will be taller than 6 inches). Targeted forest vegetation consists of brush, briers, and pine saplings and coarse woody debris up to 6 inches DBH. The contractor will provide the machinery, all the fuel, fluids, maintenance items and labor necessary to conduct the forestry mastication.

PART 6

APPLICABLE PUBLICATIONS

6. APPLICABLE PUBLICATIONS (CURRENT EDITIONS)

A Refuge Special Use Permit is required for access into the refuge after the contract is awarded. The Refuge will issue the permit which will include the following:

• A pre-entry conference between the COR, Government Representative or designee and the successful bidder representative will be required before beginning operations to insure understanding of the permit conditions and thus avoid serious conflicts.

• The contractor could be directed to change work sites with short notice due to wet ground conditions, endangered species nesting, safety of the public, and various other reasons.

• No damage should occur to residual trees remaining in the stands (>6 inch DBH)

• Except where specifically authorized by a Special Use permit, all regulations governing activities on Mississippi Sandhill Crane National Wildlife Refuge in general and specific public use regulations for Mississippi Sandhill Crane National Wildlife Refuge (including littering, possession and use of firearms, and protection of wildlife) apply.

• All mechanical treatment will be within the boundaries specified (see attached map) and coordinated with the COR, Government Representative or their designee.

• Vehicles and other equipment will be always operated in a safe manner. Both refuge personnel and the visiting public use the refuge roads. The speed limit on refuge roads is 25 miles per hour unless posted otherwise.

• Contractor and their employees shall not build fires on the refuge. The Contractor and his/her employees will be reasonably prudent in preventing and suppressing forest fires. Contractor shall be liable for all fire suppression cost resulting from his operations.

• Clean up of oil, hydraulic fluid, and other contaminants because of the operation is the responsibility of the Contractor. Spill kits required.

• The Project Leader and/or Contracting Officer Representative/Government Representative shall have authority to temporarily close all or any part of the operation during a period of high fire danger, wet ground conditions, or for any other reason deemed necessary. The government may allow an extension of the contract term if it is determined that the contractor could not complete the contract within the normal contract period due to excessive inclement weather or government caused delays that exceed a total of 14 days.

• Failure of the Contractor to comply with any of these Special Conditions, with the State or Federal law, or special refuge regulations will be sufficient cause for refusal of future Special Use Permits being granted to the permitted party.

• All work must be coordinated with the COR, Government Representative or designee.

• All refuge regulations are in effect unless otherwise designated in writing.

• No collection of plants, animals, rocks, or artifacts allowed.

• No alcohol is permitted on the refuge.

• Persons possessing, transporting, or carrying firearms on National Wildlife Refuges must comply with all provisions of state and local law. Persons may only use (discharge) firearms in accordance with refuge regulations (50 CFR 27.42 and specific refuge regulations in 50 CFR Part 32).

• Vehicle traffic is restricted to gravel roads designated as open except as marked on attached map of the project work area.

• Contractor is responsible for daily cleanup of work area.

• Application will not be permitted when the ground is wet and subject to rutting or severe soil compaction. The Contractor will be required to fill any ruts greater than 6 inches deep made because of their operation.

PART 7

ATTACHMENT/TECHNICAL EXHIBIT LISTING

7. Attachment/Technical Exhibit List:

7.1. Attachment 1/Technical Exhibit 1 – Performance Requirements Summary

TECHNICAL EXHIBIT 1

Performance Requirements Summary The contractor service requirements are summarized into performance objectives that relate directly to mission essential items. The performance threshold briefly describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success.

Performance Objective (The Service required—usually a shall statement)

Standard Performance Threshold (This is the maximum error rate. It could possibly be “Zero deviation from standard”)

Method of Surveillance

PRS # 1.

The contractor shall provide mastication and mechanical reduction of vegetation and wildland fuels within identified treatment area on Mississippi Sandhill Crane National Wildlife Refuge.

The contractor provides competent mastication and mechanical fuel reduction of the entire treatment area of up to 288 acres. Final total acreage and treatment area boundary will be determined based on per acre bid rate and funds available.

A deviance from final total acreage of up to 10% is considered acceptable.

Actual treated area will be visually inspected and compared against final awarded acreage.

PRS # 2

The contractor shall masticate all wildland fuels within the treatment area up to 6 inches DBH.

Residues from the mastication process will be less than 2 feet in length and 2 inches in diameter.

20% of total volume Random sample of vegetation residues.

PRS # 3

The contractor shall masticate all stumps down to ground level.

Stumps from masticated trees, saplings and brush will be taken down to ground level / mineral soil.

A deviance of up to 10% of total number of stumps is considered acceptable.

Random sample of treatment area.