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substantially replaced by recent regulation amendments, specifically new Rule 4.15.11. <br />Please amend the section to clarify sampling plans and statistical methods for <br />future demonstrations of revegetation success, and to ensure that sampling plans <br />and statistical formulas comply with applicable provisions of 4.15.11. <br />New Horizon 2 Site Description and Land Use Information (Section 2.04.3) <br />6. Rule 2.04.3(2)(a) requires a map and supporting narrative describing the pre-mining land <br />uses in the permit area, in accordance with the land use categories established in the <br />land use definition in Rule 1.04. Narrative and tables in Section 2.04,3 of the application, <br />as well as Map 2.04.10-1 and narrative in the Vegetation and Land Use Overview of <br />Section 2.04.10 seem to use vegetation types and land use categories somewhat <br />interchangeably, which leads to some confusion. <br />Based on our interpretation of the permit information and site observations, primary pre- <br />mine land uses pursuant to the land use categories in Rule 1.04 (71) would include <br />"Cropland", "Pastureland", and "Rangeland". Vegetation types within the Cropland land <br />use category would include irrigated grain crops and irrigated hayland (alfalfa hay and <br />grass hay sub-types). Vegetation types within the Pastureland land use category would <br />include irrigated and dryland forage plantings (e.g. irrigated pasture and dryland pasture). <br />Some lands currently designated "irrigated pastureland" in the permit, may best fit in the <br />"Cropland" land use category, while other areas with the same current designation might <br />best fit the "Pastureland" land use category. Proper designation would depend on the <br />level of management, and whether the land is used for hay production on a relatively <br />regular basis, or only "occasionally', if at all. The "Rangeland" land use category would <br />include the various sagebrush vegetation types and the pinyon/juniper community. Small <br />weedy waste areas that have developed at field corners, low spots, stock concentration <br />areas, etc., would logically be included within the dominant adjacent land use category. <br />Similarly, the swale vegetation type that has developed within the Pastureland and <br />Cropland land use areas, should be included within the respective land use category <br />(Pastureland or Cropland). <br />Please submit a premining land use map, delineating land use categories in <br />accordance with Rule 1.04(71), and corresponding amended narrative and tables <br />for inclusion in Section 2.04.3. <br />New Horizon 2 Vegetation Information (Section 2.04.101 <br />On page 2.04.10-89, there is discussion of the fact that a new dryland pasture reference <br />area was established in 2005, immediately adjacent to the former dryland <br />pasture/rangeland {combined) reference area, because of the number of shrubs in the <br />combined reference area. Attachment 2.04.10-3 presents the results of the 2005 <br />sampling of the new dryland pasture reference area and comparison of the 2005 data for <br />the new area to the 1999 data for the combined reference area. The data indicate that <br />shrub cover was somewhat higher in the combined area compared to the new dryland <br />reference area, but in both areas shrub cover was relatively low (1.2% and 3.3%, <br />respectively}. The shrub cover may have increased in the combined area since 1999, but <br />this was not documented. Total perennial cover and herbaceous production levels for the <br />two areas were quite similar between sampling years, however perennial (orbs were the <br />dominant life form in the new dryland area in 2005, whereas perennial grasses were <br />dominant in the combined reference area in 1999. Perennial grass production in the <br />combined reference area in 1999 was 424 pounds per acre, compared to 32.7 pounds <br />per acre in the new reference area in 2005. It is not clear whether the reversal with <br />respect to relative dominance by grasses (1999 combined) and forbs (2005 new dryland) <br />