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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Sanborn Creek/Elk Creek Mine. The primary purpose of the <br />inspection was to evaluate vegetation in the location of the proposed II West Coal Refuse Facility. <br />Oxbow Mining LLC did not collect any additional baseline data for the proposed new disturbance. <br />Jim Kiger accompanied me on the inspection. The weather was hot and the azea was very dry. <br />In the Sanborn Creek/ Elk Creek permit there is a vegetation study that was conducted in 1982 to <br />provide vegetation baseline data and to serve as an `extended' reference area. The report is found in <br />Exhibit 2.04-E6 of the permit and the map showing the vegetation communities and sample locations <br />is Drawing No. 2.04-M8. The area surveyed in the1982 baseline study included the area OM LLC <br />proposes to disturb with the construction of the II West Coal Refuse Facility. It is a mountain shrub <br />and juniper woodland community. Dominant species are juniper and Gambels oak. A number of <br />Fendler cliffrose are scattered throughout the proposed disturbed area. Indian ricegrass is the <br />dominant grass. Soils are rocky and shallow. <br />The proposed disturbed azea is similar in species, form and composition to the data found in the <br />baseline survey. Based on this inspection it is apparent that the baseline survey is representative of <br />the azea to be disturbed. No additional vegetation will need to be collected. The `extended' <br />reference area will be reduced in size as a result of this disturbance, but there is sufficient <br />undisturbed land that will more than suffice for a reference area. It will be necessary to include a <br />discussion of the proposed disturbance and the associated vegetation in the waste pile revision <br />application as Jim Burnell addressed in his August 6, 2003 adequacy letter, number 13. <br />