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!. ~ + • <br />l ~' <br />~- <br />reflect the original proposal. The original approval designated <br />several different land uses including undeveloped land, cropland, <br />grazing land, residential etc.. Map 3.1-2 shows these lands per <br />pre-mining disturbance and Volume 1 page 4-72 of the permit <br />application states that this map also constitutes the post-mining <br />land use map. Any submittal should reflect the uses as outlined in <br />the original map or clearly demonstrate the requested change per <br />rule 4.16. <br />Even if the Division allows a land use change, the proposed use <br />will not be pasture for the entire reclaimed area due to the fact <br />that it can not all be managed as "PASTURELAND" which requires <br />various cultural inputs such as seeding with the appropriate seed <br />mix, fertilization, irrigation, haying or mechanically removing <br />forage, etc.. Clearly the operator has not contemplated this type <br />of management (pastureland) for all of this reclaimed area as <br />evidenced by the use of two different seed mixes, the references to <br />using only limited irrigation on a portion of the area, using most <br />of the area for grazing, etc.. <br />The revised text does seem to reflect the multiple uses that <br />existed prior to mining, however, figure 4.7-3 does not delineate <br />these uses. Please have the operator submit a new map or figure <br />with an accompanying table that CLEARLY delineates the proposed <br />uses and their respective acreages. The land use terms should <br />correspond to those that are in rule 1.04(71). This will probably <br />be something like rangeland, pastureland/cropland, residential, <br />commercial, undeveloped, etc.. <br />SUCCESS STANDARDS <br />3. The operator has proposed at the 11th hour to change the <br />success standards for revegetation per rule 4.15.7(2)(d)(vi). This <br />rule does allow for disturbed areas of 40 acres or less to have a <br />numerical standard assigned for determining revegetation success. <br />However, this is based on data for the area to be disturbed which <br />is obtained from statistically valid sampling procedures and <br />collection methods prior to any disturbance. The operator may have <br />done this but did not indicate that it was done and also did not <br />propose a standard. If they want to propose the use of a standard <br />please have them submit the statistically valid pre-mine data and <br />a proposed standard. In the meantime the success standard will be <br />a comparison between the approved reference area and the reclaimed <br />area as outlined in the permit application on page 4-66. <br />For the pastureland/cropland (irrigated and intensively managed <br />area) success demonstration I will propose a more clearly defined <br />standard than what the operator has submitted. The reclaimed <br />pastureland/cropland shall be considered successful if the <br />production or yield on the reclaimed pastureland/cropland is at <br />least 90$ of the production on a nearby and similarly managed <br />"reference pasture/crop area" with 90$ statistical confidence. <br />This can be sampled per the production sampling scheme laid out in <br />the permit on page 4-66 or the operator may also do a total <br />