2018-02-08_PERMIT FILE - C2010089 ‎(2)‎

• Permit No: C2010089
• IBM Index Class Name: PERMIT FILE
• Doc Date: 2/8/2018
• Doc Name: Revegetation Plan
• Section_Exhibit Name: Section 2.05.4‎(2)‎‎(e)‎
• Media Type: D
• Archive: No

NHN owns the Dryland Pasture reference area and controls all of the management aspects of this
site. The reference area will be protected from domestic livestock grazing. Wildlife (deer, elk)
winter grazing will still be allowed, as is on the NHN Dryland Pasture reclamation areas.
4.0 Revegetation Success Criteria and Statistical Procedures
4.1 Irrigated Pasture/Cropland
The Garvey Property requires a special performance criterion for production to meet its post -
mining land use of Irrigated Pasture/Cropland because the land owner has requested an alfalfa
field. While this revegetation still would be considered an irrigated pasture, using the established
Irrigated Pasture Reference Area or baseline data, which are both comprised primarily of grasses,
seems inappropriate for the production success comparison. On the other hand, ground cover is
still appropriate to compare with the baseline data because ground cover primarily serves to
demonstrate erosion protection.
Production Success Criterion
The production success criterion for the Garvey Property will be derived from U.S. Department
of Agriculture - National Agricultural Statistics Service(https://quickstats.nass.usda.gov/), which
provides annual yields by county and commodity. Success comparison will occur against either
the Montrose County current annual alfalfa yield or the long term average (if the annual data is
not available). The following table displays the annual alfalfa yields for Montrose County for the
last 20 years (1997-2016). The resulting long term average is 3.41 air dry tons per acre.
Montrose Countv Alfalfa Yields (USDA - National Agricultural Statistics Service)
Year
Tons per Acre
Year
Tons per Acre
Year
Tons per Acre
Year
Tons per Acre
1997
3.85
2002
3.15
2007
3.60
2012
3.35
1998
3.85
2003
3.70
2008
2.75
2013
2.65
1999
3.75
2004
3.50
2009
3.65
2014
2.45
2000
3.40
2005
3.60
2010
2.80
2015
3.55
2001
3.60
2006
4.10
2011
3.40
2016
3.40
Once the alfalfa yield (current annual or long term average) is obtained from the USDA, the
value needs to be discounted to only consider the first cut of alfalfa (success testing will occur
immediately prior to the first cut). A Colorado State University Extension study evaluated forage
yields of 20 alfalfa varieties at the Southwestern Colorado Research Center at Yellow Jacket,
Colorado in 1996-1999 (Colorado Alfalfa Variety Performance Results) and found that the first,
second, and third cut yielded 2.14, 1.87, and 1.00 tons per acre, respectively. Therefore, the first
cut accounts for 42.7% (2.14/5.01) of the annual yield. For example, the long term average yield
(3.41 air dry tons per acre) is multiplied by the first cut percentage (42.7%) to provide an
approved standard (1.45 air dry tons per acre) for revegetation success testing to occur
immediately before the first cut. A similar process would occur if current annual yields are used.
In accordance with Rule 4.15.8(4), herbaceous production of the revegetated area shall be
considered acceptable if the revegetated area production is not less than 90% of the approved
standard using approved statistical testing and demonstration techniques.
Section 2.05.4(2)(e) Page 8 of 14 January 2018 (PR -02)