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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. This was a partial inspection of the New Horizon Mine, conducted by Dan Mathews of the DMG Grand Junction Field Office, 101 South 3id, Suite 301, Grand Junction, CO 81501. Weather was clear and warm, with brief rain showers. The purpose of the inspection was to discuss various issues associated with the revegetation plan and standards of success. A number of issues had been raised by the Division during the most recent mid-term permit review, and additional issues have been raised by the operator, notably problems with the approved dryland pasture reference area and problems with the approved production success standard for irrigated pasturelands. Prior to on-the-ground inspection, a meeting was held at the mine office to discuss some of the issues of concern. Individuals present at the meeting in addition to myself, were Ross Gubka of Western Fuels- Colorado (WFC), consultants Greg Lewicki, Steve Boyle, and David Koehler, and Jim Boyd, NRCS District Conservationist. Following the meeting, several field sites were visited; the current dryland pasture reference area in a fenced site on Nucla Airport property, the reclaimed dryland pasture parcel known as the Rice Tract, in the NH-1 area, and a pre-law spoil reclamation area across the county road from the Rice Tract which was reclaimed several years ago by the DMG/AML program, using a relatively diverse rangeland seedmix. No final conclusions were reached at the meeting, which served primarily as a brainstorming session in which a number of issues were presented, and possible approaches to the problems were suggested and discussed. My notes from the meeting include the following points: Irrigated Pasture Issues • Current Standards may be inappropriate for reclaimed areas within portions of the permit area, or perhaps the entire permit area (due to prevalence of shallow, low productivity soil types that are not typically irrigated). • There may be a need for two separate irrigated pasture production standards, based on soil types, replaced thickness, etc. (county road may be likely logical easUwest dividing line). • Production data from 1987 and 1999 may be of significant value to development of standards and logic for changing standards, but detailed precipitation records applicable to the 1987 and 1999 growing seasons will need to be presented (were these "typical" years, above normal or below normal?). Production records (Farm Service Agency) for other irrigated lands in the region may be of use, for making interpretations as to the value of these data. • Correlation of pre-mine soil types with respread reclamation soil thickness? • Revised technical standard would need to be based on soil factors, available records and correlations, input from focal farmers, and NRCS (Norwood District as well as Charlie Holcomb, Area Agronomist in Grand Junction). Use of published data or written records should be relied upon to the extent possible. Dean Stindt, formerly with NRCS Norwood now with BLM may also be of assistance. • "Quality Factors" (i.e. composition) should also be addressed for irrigated pasture and hayland. Dryland Pasture Issues • The most practical management approach for the Rice Tract would appear to be interseeding with dryland alfalfa and grasses, possibly include four-wing saltbush. However, interseeding not allowed under current regulations for pastureland. Only rangeland under specific conditions. Land use change was mentioned as a possible option. Regulatory change might be another option (would need input from NRCS, County Extension service, etc. to support pastureland interseeding as a "normal husbandry practice") to support regulation change. For interseeding, consider "No-Till" drill, or broadcast seed followed by light (spring-tooth type) harrow. • Early fall herbicide application, shortly after germination of storksbill, might be warranted to control competition and enhance potential for establishment of interseeding if conducted in the Rice Tract. Prairie dog control warranted? • If suitable reference area(s) cannot be located for dryland pasture, technical standard may be warranted; NRCS range site descriptions applicable to the permit area may provide some basis or guidance, likely