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2 <br />Areas. The NOAA Altas 14 precipitation values are available on-line on the NOAA <br />website. <br />K= Soil erodibility factor. OM used K=0.2. The soils are Absarokee-Work loam, <br />Beenom-Absarokee assoc., and torriorthents. <br />2. Please have OM define how they derived the K factor=0.2. <br />The Division accessed the NRCS web soil survey on line. We defined an <br />area of interest for the Elk Creek mine, and look at the “soil report” tab, <br />“Soil Erosion” tab, “RUSLE2 Related Attributes” soil report, the results <br />show the Absarokee-Work Loam soils as having a K factor of 0.32 and <br />hydrologic group of D/C. The Beenom-Absarokee loam soils have a K <br />factor of 0.32 and hydrologic group of D. The torriorthent complex soils <br />have a K factor of 0.28, with a hydrologic group of B or C. The Division <br />is unsure where the operator arrived at a K factor of 0.2 for these soils. <br />LS= length of slope factor. Elk Creek used 10.57 from measurements at West Elk Mine. <br />3. Please request OM to derive the LS factor for the average slope that would <br />be encountered on the reclaimed areas at the Elk Creek Mine. The <br />application doesn’t clarify how this value was derived for the West Elk <br />mine. Therefore, the Division is unable to determine if this value is <br />appropriate for the Elk Creek reclaimed area. <br />P= Control practice based pm soil conservation practices. Elk Creek used 1.0 for native <br />areas and unmanaged. The Division concurs with this assumption for the P value. <br />The calculation equals C=0.194. Elk creek proposes vegetative cover of 20% total <br />vegetative cover. “Total vegetative cover shall include live vegetative cover of all plants <br />encountered during quantitative cover sampling.” <br />4. In accordance with Rule 4.15.1(1), the operator needs to establish on all <br />affected land a diverse, effective and permanent vegetative cover. Please <br />note that this cover cannot include noxious species for reclamation <br />success. It has been Division policy to allow up to 10% relative cover of <br />annual/biennial plants to count towards reclamation success, since annual <br />and biennial species are not considered permanent cover. <br /> <br />5. On revised page H-7, OM includes section 2.6 regarding Grazing, Rule <br />4.15.5 (1) Domestic livestock grazing must not commence until one year <br />after seeding or planting and shall be managed to promote the postmining <br />land use. Proposed page H-7 states that grazing is allowed on lands <br />owned by Hotchkiss ranches, BLM, or FS, and OM does not control the <br />activity. Please note that OM is still responsible for keeping livestock off <br />newly seeded areas in accordance with Rule 4.15.5 (1). <br /> <br />6. Oxbow Mining, LLC included seed mixes to be used and approved on US <br />Forest Service land, Seed Mix Table 5. Of note, the previously approved <br />Forest Service seed mix stated that a minimum of three (3) forb species