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<br />r i <br />• rotation with grasses and legtunes, and includes row crops, small grain crops, hay crops, <br />nursery crops, orchard crops, and other similaz specialty crops." While much of the <br />adjacent land does fall under the definition of "Cropland", the small community, <br />including a Jr./Sr. High School, located immediately North of the permit area, would not <br />be considered cropland. The Map should reflect that a portion of the adjacent area is <br />residential. Please correct the Pre-mine Land-use map to include Residential land use. <br />~o- This correction should also be made on the pre-mine land use description found on page <br />,~ ~~ y 2.04-1. <br />30. Irrigated alfalfa hay production was reported as an average for all of Las Animas County <br />\~~( based on 1995 growing season. (page 2.04-2) The Division is concerned that pre-mine <br />J productivity for irrigated hayland may not reflect the productivity specific to the mine <br />area. Las Animas County has productive agricultural lands east of the City of Trinidad, <br />as well as poor productivity hilly lands in the west of the county. Moisture in 1995 was <br />unusually heavy during the eazly portion of the growing season. The Division is <br />concerned that Lorencito Coal Company may be setting the pre-mining irrigated lands <br />productivity higher than was could be obtained at the mine site during an average year. <br />LCC should provide local NRCS, or Agricultural Extension Service data specific to the <br />area that accounts for an average of several yeazs productivity. <br />~, Rule 2.04.4 Cultural and Historic Resource Information <br />• p~`' p5,3,1. At this time, the inventory report for work completed in 1996 has not been received by <br />5 S~N~' \ the Division. The State Historic Preservation Office is expecting identification of cultural <br />`. \~ resources in the areas so that they may evaluate each site in terms of National Register <br />C __,~~` criteria. Avoidance and/or data recovery may be necessary at eligible or potentially <br />~t`~, eligible sites. Once SHPO has determined eligibility for all sites in the affected area, the <br />Division may proceed with approval or conditional approval as required under Rule <br />2.07.6(2)(e). <br />Rule 2.04.5 General Description of Geology and Hydrology <br />b~ 32. Under the interburden section, reference is made to the "mineable N, O, J, and L seams". <br />Are these seams to be mined by the contour operation? <br />D~ 33. Rule 2.04.6(3)(a)(iv) information should be provided for all portal face-up areas to be <br />affected within the f rst S year permit term. Please refer to this Rule for the specific <br />information required. <br />D~ 34. Exhibit 6 text states "swell factors of 25 percent were determined by field observation and <br />using percentages consistent with historical practices." What specific field observations <br />• or methods were used? What is meant by historical practices? Please expand this section <br />of text as appropriate. <br />