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Rule 4.04: Support Facilities <br />As noted above, WFC primarily uses the offices at the New Horizon Mine but does have a small <br />facilities area on the southern end of this permit. This area hosts an office trailer, two diesel <br />storage tanks, two storage containers, a wash bay, an elevated water stand, power poles / yard <br />lights, and a parking area. We measured these features and compared actual sizes to <br />measurements provided on Map 2.05.3(3)-1, Facilities Map. All sizes provided on Map <br />2.05.3(3)-1 are either accurate or overestimated, which will lead to accurate or overestimated <br />bond cost calculations. <br />Rule 4.05: Hydrologic Balance <br />Ponds 1 and 2 both contained small amounts of water but were not discharging. Primary and <br />emergency discharge structures are in good repair. Although we did not walk diversion ditches <br />during this partial inspection, we did observe portions of the NHN-002 North ditch which was in <br />good functional condition. <br />Rule 4.06: Topsoil <br />There are four designated topsoil stockpile locations on site: two Progresso loam and two mixed <br />topsoils. The northwestern mixed topsoil stockpile has been reseeded several times with limited <br />success. WFC reconfigured this stockpile last summer to decrease the slopes and enable drill <br />seeding. The stockpile was drill seeded with annual species last summer but vegetative cover is <br />still lacking. The southeastern mixed topsoil stockpile has better vegetative cover, but also <br />remains somewhat sparse. Perimeter berms are in place to protect topsoil resources, but <br />improved vegetative cover would be ideal. WFC is aware of this and, as noted above, has taken <br />positive steps to improve vegetative cover on topsoil stockpiles. Progresso soils are now live - <br />hauled from active mining advance areas and spread on backfilled and graded lands to avoid <br />stockpiling which can degrade soil quality. <br />Rule 4.15: Revegetation <br />The irrigated pasture reference area was cut and baled the day prior to this inspection, making it <br />difficult to accurately identify plant species. Grasses (potentially Kentucky bluegrass, fescue, <br />brome, etc.), alfalfa (Medicago sativa), clover (Trifolium repens), English plantain (Plantago <br />lanceolata), and dandelion (Taraxacum officinale) were observed. The reference area is fenced <br />to control access. Cattle are grazed in the area after the final hay cutting is collected to clean up <br />residual vegetation. Flood irrigation is employed here, whereas siderolls and center pivots are <br />used to irrigate reclamation. Flood irrigation is not feasible on reclaimed lands because <br />infiltration rates are too high. Although the irrigation practices differ, all areas include irrigated <br />crop species and so utilizing revegetation success criteria set by growth in this reference area <br />(cover, species composition, productivity in lbs/acre) appears appropriate. <br />The currently -permitted dryland pasture reference area is located at the Nucla airport. WFC has <br />proposed to replace this reference area with the "old Peabody sage reference area" which was <br />used for the New Horizon Mine permit (#C-1981-008). This change is proposed in Technical <br />Revision No. 14 (TR -14), which DRMS has not yet reviewed or approved. We briefly inspected <br />the airport reference area. It appears that the airport has mown large portions of land. Mr. Bowles <br />indicated that the soil type varies from that found within the permitted disturbance area. The <br />facts that WFC is experiencing difficulties coordinating management of the reference area with <br />2 1 Page <br />