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rotation with grasses and legumes, and includes row crops, small grain crops, hay crops, nursery crops, orchazd crops, and other similar specialty crops." While much of the adjacent land does fall under the definition of "Cropland", the small community, including a Jr./Sr. High School, located immediately North of the permit azea, would not be considered cropland. The Map should reflect that a portion of the adjacent area is residential. Please correct the Pre-mine Land-use map to include Residential land use. This correction should also be made on the pre-mine land use description found on page 2.04-1. 30. Irrigated alfalfa hay production was reported as an average for all of Las Animas County based on 1995 growing season. (page 2.04-2) The Division is concemed that pre-mine productivity for irrigated hayland may not reflect the productivity specific to the mine azea. Las Animas County has productive agricultural lands east of the City of Trinidad as well as poor productivity hilly lands in the west of the county. Moisture in 1995 was unusually heavy during the early portion of the growing season. The Division is concerned that Lorencito Coal Company may be setting the pre-mining irrigated lands productivity higher than was could be obtained at the mine site during an average year. LCC should provide local NRCS, or Agricultural Extension Service data specific to the area that accounts for an average of several years productivity. Rule 2.04.4 Cultural and Historic Resource Information 31. At this time, the inventory report for work completed in 1996 has not been received by the Division. The State Historic Preservation Office is expecting identification of cultural resources in the areas so that they may evaluate each site in terms of National Register criteria. Avoidance and/or data recovery may be necessary at eligible or potentially eligible sites. Once SHPO has determined eligibility for all sites in the affected area, the Division may proceed with approval or conditional approval as required under Rule 2.07.6(2)(e). Rule 2.04.5 General Descrintion of Geology and Hydroloav 32. Under the interburden section, reference is made to the "mineable N, O, J, and L seams". Are these seams to be mined by the contour operation? 33. Rule 2.04.6(3)(a)(iv) information should be provided for all portal face-up areas to be affected within the first 5 year permit term. Please refer to this Rule for the specific information required. 34. Exhibit 6 text states "swell factors of 25 percent were determined by field observation and using percentages consistent with historical practices." What specific field observations or methods were used? What is meant by historical practices? Please expand this section of text as appropriate.