Laserfiche WebLink
III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />Phase 2 bond release. Improved management of this parcel would appear to be necessary for it to <br />meet Phase 3 bond release criteria in the future. <br />The NH-2 "Phase 3" irrigated pasture areas observed were dominated by desirable, productive pasture <br />grasses with a significant alfalfa component. Vegetation cover appeared to be in excess of 70%, with <br />minimal bare ground exposure. NH-2 "Phase 2" irrigated areas were similar in appearance to the <br />"Phase 3" areas, with the exception of one "Phase 2" parcel, which had not yet been irrigated this <br />growing season. Although species composition appeared to be similar to other NH-2 irrigated pasture <br />areas, cover and production were obviously lower than in parcels that had been irrigated. Ross Gubka <br />said that the area had not been irrigated due to shortage of labor to operate the side roll sprinklers. <br />The lack of irrigation could possibly impact achievement of Phase 2 cover standards this year, <br />and continued problems with irrigation scheduling could impact long term success in the <br />irrigated areas. <br />The NH-1 "Rice Tract" dryland pasture area was also observed. As noted in previous inspections, <br />perennial cover and production is low in this area, essentially limited to clumps of Russian wildrye. The <br />winter annual forb, stork's bill, is prevalent, and has already matured seed and begun to dry out and <br />shatter. It appears evident that perennial vegetation cover remains significantly lower in the reclaimed <br />area than in the Dryland Pasture reference area, due primarily to higher cover of perennial forbs and <br />sub-shrubs in the reference area. WFC does not plan to sample the Rice Tract dryland pasture this <br />year for inclusion in a Phase 3 bond release application. The area was previously approved for Phase <br />2 bond release. WFC is considering interseeding of this area, contingent upon approval of a regulation <br />change that would allow for approval of pastureland interseeding as a normal husbandry practice. <br />Two dryland pasture parcels were observed in the NH-2 mine block. One parcel had been reseeded <br />over 9 years previously (south of BB Road) and will be included in the "Phase 3 sampling area" this <br />year; the other parcel had been seeded 4 or 5 years previously, and will be included in the "Phase 2 <br />only' sampling area this year. The older area south of BB Road was dominated by Russian wildrye, <br />with a modest component of other perennial grasses, primarily crested wheatgrass and western <br />wheatgrass, and some alfalfa. The younger area north of BB Road appeared to exhibit higher cover <br />and production, with a more equitable representation of the various seeded species. Alfalfa component <br />appeared to be notably higher than in the older area. <br />Modification of the dryland pasture seedmix to include adapted shrub and sub-shrub species such as <br />fourwing saltbush and forage kochia was discussed. These species are adapted to the soil and <br />climatic conditions in the mine area, provide livestock forage, and would be expected to establish and <br />persist better long term under dryland conditions than alfalfa. The possibility of reclaiming some of the <br />non-irrigated areas to a rangeland postmining use, with a wider variety of shrubs, forbs, sub-shrubs <br />and native grasses, was also discussed. Landowner desires regarding postmine land use and <br />seedmixes would need to be considered if such changes are proposed. The need to balance <br />irrigated acreage with irrigation water availability was also discussed, and will need to be <br />addressed within the pending TR-55 application. Documentation from NRCS or other <br />recognized authorities regarding the acreage of pasture that can be irrigated per share of <br />irrigation water, to achieve reasonable production levels under prudent management in the <br />region, will need to be provided within the application. <br />WFC may wish to make some refinements to the Premine VegetationlLand Use map, based on <br />appropriate documentation, to delineate certain land parcels as "abandoned irrigated land". One such <br />area to the west of the current mine pit was observed during the inspection. The area had apparently <br />atone time been irrigated and managed, but at present has the appearance of a waste area, and has <br />been overtaken by noxious weeds (primarily Russian knapweed) and prairie dogs. WFC indicates that <br />aerial photo documentation demonstrates that irrigation and active management of the area had <br />ceased prior to acquisition of the property by the mine operator. <br />5 <br />