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production data indicate 64.1% of the 1660 pounds of oven dried forage per <br />acre is of moderately tolerant species and 25.3% is of moderately sensitive <br />plants. There are about 91 acres in Pasture 2. <br />The irrigated pastures of the Trout Creek alluvial alley floor region support <br />25.8% of moderately tolerant species and 15.3% of moderately sensitive <br />species. This region contains about 246 acres of irrigated land which is <br />generally cut for hay, 42 acres of irrigated land which is usually managed as <br />pasture, and 69 acres of irrigated land which is more typical of a sagebrush/ <br />meadow type community. Production estimates for Pasture 11 indicate <br />moderately tolerant species upply 27.9% of the total amount and moderately <br />sensitiv eplants are 34.6%. Approximately 4550 pounds of oven dried forage <br />are produced. Pasture 11 covers about 12 acres. <br />The portion of the Fish Creek alluvial valley floor which is currently <br />irrigated, Pasture 13, supports about 34.3% of moderately tolerant species <br />and .5%of moderately sensitive species. The Sagebrush/Meadow region has <br />18.2% of moderately tolerant plants and 3.3% of moderately sensitive plants. • <br />These areas cover about 57 and 1253 acres, respectively. <br />The Colorado Mined Land Reclamation Division (CMLRD) has chosen to establish <br />the material damage standard for irrigation waters at 1000 umhos/cm. This <br />standard is based on a conversion factor of 1.5 to describe the salinity of <br />the soil and the premise that moderately sensitive species dominate the areas <br />of concern. Information and data obtained by TCC do not support the <br />contention that a 1.5 conversion factor is applicable for the irrigated land <br />downstream of the Foidel Creek Mine nor that moderately sensitive species <br />dominate the area. <br />CMLRD has used a 1.5 conversion factor to describe the salinity of the soil <br />after the applicatio^ of irrigation water of a particular salinity. For <br />example, applying irrigaton water of 2000 umhos/cm could result in soil <br />salinity of 3000 umhos/cm. <br />As discussed under Rule 2.06.8(6) of the Twentymile Coal Company Life-of-Mine <br />Permit submittal (revised 5/22/86), the conversion factor is not appurtenant • <br />8 Revised 10/1/86 <br />