This report is presented in three sections addressing two reports and the sulfur dioxide issue interspersed in their reports. These are: 1. Sulfur Dioxide Issues 2. Redente Report 3. Keammerer Report Key points developed under each of these sections are summarized below. Sulfur Dioxide --ARCO has maintained that the conditions found on the injured areas are due solely to SO2 emissions that killed the vegetation and that subsequent erosion has impeded recovery. ARCO summarily dismisses arsenic and metals as causative agents of the injury. The literature review undertaken as part of this current review was focused on (a) identifying the mechanism of injury caused by SO2 emissions both at the level of individuals and communities; (b) characterizing the recovery of injured individuals and plant communities; and (c) residual effects in terrestrial systems following SO2 emissions. The primary long term effects in plant communities around historical smelting sites are caused by soil acidification and metals contamination. After SO2 emissions are reduced, plants rebound to preexposure levels within one to two growing seasons. Communities that were altered by SO2 emissions are likely to begin to recover in a manner similar to any other transient agent (stressor). The only long lasting effect that is somewhat unique to SO2 effects is the acidification of soil. In the terrestrial impact areas (Smelter Hill, Stucky Ridge, Mt. Haggin), soil pH has not dropped to levels that are innately phytotoxic. Therefore, no true residual impacts are attributable to SO2. Keammerer Report -Rebuttals to Keammerer's critique of the State's Phytotoxicity study are provided. Many of the challenges to the State's approach and conclusions appear to be based primarily on interpretations of Redente's study. As detailed in the review of Redente's report and supporting materials, rather than contradicting the State's findings, the data strongly support the State's position.Keammerer's study design relies heavily on maps of the injured areas. The criteria used to prepare the maps are not provided in either the report or the materials disclosed to the State. Working from these maps, Keammerer developed a sampling strategy that had the effect of over-stating the quality of vegetation of the area.His selection of control areas was based on the vegetation conditions that he was attempting to measure. This violates the fundamental principle of using independent criteria to quality controls.Because of these nuances of sampling, the quantitative data overstates the quality of vegetation of the impact area throughout his report.Nevertheless, the central descriptions developed in his studies corroborate the findings of the State.If one refers to the percentage cover rather than relative cover, it is clear that Dr. Keammerer is describing areas of very little vegetation. Notwithstanding his claim that the areas are not dominated by noxious weeds, his quantitative data shows high proportions of weeds including those designated as noxious weeds. Keammerer claims...