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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during <br />the inspection. Comments also describe any enforcement actions taken during the inspection and the <br />facts or evidence supporting the enforcement action. <br />This was a partial inspection conducted by Janet Binns of Colorado Division of Minerals and Geology. <br />Mr. Ross Gubka and Mr. Tony Adkins accompanied the inspection. The weather is warm and the mine <br />site is very dry. This mine is an active surface mine with one active pit. <br />The focus of this inspection was to visually evaluate WF-C's proposed dryland pasture reference area. <br />Reclaimed dryland pasture and irrigated pastures planned to be sampled for bond release purposes were <br />evaluated as well. Dryland pasture at East end of the mine is very dry. This parcel is visually dominated <br />by Russian wildrye, Alfalfa, some Timothy, and a fair amount of Redstem filaree. Tansy mustard was <br />present sporadically. Though annual species continue to be present in this area, no noxious species were <br />noted. The cover in the dryland pasture parcel was thin with a fair amount of bare ground and annual <br />species amidst the perennial species. Erosional features were not evident. The Rice tract on the New <br />Horizon No. 1 (NHl) area exhibits similaz conditions to the dryland pasture parcel on the east side of the <br />mine. Rice Tract vegetation appeazed less consistent, and visually had a patchy appearance (Photo 1). <br />An annual forb, Redstem filaree, was consistent throughout the perennial stand. An absence of <br />Cheatgrass was noted. No noxious species were observed. The stand is sparse but existing vegetation <br />appears healthy. <br />Irrigated pastures exhibit excellent cover, few weedy species, and no noxious species. Irrigated pasture <br />was visually dominated by perennial pasture grasses and alfalfa. WF-C reports that alfalfa <br />concentrations diminish after approximately 5-growing seasons. Local farming practice is to interseed <br />alfalfa into irrigated pasture periodically. WF-C contracts with local fanners for reclaimed pasture <br />management. <br />The airport dryland pasture/rangeland reference area was observed (Photo 2). This reference area <br />visually looks similaz to the surrounding rangeland. The airport reference area is fenced and grazing is <br />currently not permitted within the fenced airport property. Fourwing saltbrush (Atrtplex canescens) was <br />present periodically in the rangeland reference area with small young plants present in the understory. <br />Perennial grasses are sparsely distributed through out, perennial scazlet globemallow (Spharealcia <br />coccinea), annual mustards, Tumble mustard (Sisymbrium altissimum), and redstem filazee (Erodium <br />cicutarium) aze consistent throughout. Small saltbrush were evident indicating shrub species are <br />increasing in this azea. There is no woody stem requirement on the reclaimed pasture azeas on the mine. <br />WF-C's concern with utilizing the currently approved Dryland pasture(Rangeland reference azea for <br />both post-mining land use compazisons adds the cover attributed to shrub species into the cover values. <br />Some of the Fourwing saltbrush are very lazge and may add a considerable amount of additional cover <br />not comparable to any species seeded in the reclaimed dryland pasture areas. <br />The proposed Dryland pasture reference azea (Photo 3) is located adjacent to the approved Dryland <br />pasturelRangeland reference area. WF-C proposes to use the currently approved Dryland <br />pasture/Rangeland reference azea only asRangeland reference area and add a new Dryland pasture <br />reference area. The proposed Dryland pasture reference are~flagged on the ground visually compares <br />favorably with the approved reference area but lacks the shrub component. Several lazge Juniper trees <br />were included in the proposed reference area. WF-C may propose that the tree species will not be <br />Page 3 of 5 <br />