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Memorandum To: Tom Kaldenbac~ From: Janet Binns Date: 3/07/02 ~, Re: RAG Empire Corporation, TR-33 adequacy responses, Eagle 5 & 9 Mines File: C:/jhb/C81044/cropland reference area CC: Dan Hernandez The Division has serious concerns regarding RAG Empire Corporation's proposed pasture reference area. RAG Empire collected vegetation data on a proposed pastureland reference area near the Eagle #9 Portal in response to Stipulation No. 10, and requested by the Division during Permit Renewal No. 3 (RN-03), letter dated June 24, 1998. RAG Empire sampled [he proposed reference area June 26-27, 2001. The proposed reference area is shown on Map 20, Revised 3/3/97, as Reference Area "D". Production, cover and diversity were sampled. Cover was 18%. Production measured 833 lb./acre (0.42Tons/acre). The existing community would be considered a non-irrigated hay. I looked back at the wheatfield production at the Portal #9 azea included as baseline in the Eagle 5 & 9 permit, Table 70. Pre-mining wheatfield production was 1026 lb./acre (0.513 T/acre). Moffat County's agricultural statistics, reported by USDA for 2000, averaged 18001b./acre for non-irrigated hay. An adjacent mine, Trapper Mine, collected non-irrigated hay production data in 2001. Trapper's non-irrigated hay reference area measured 66741b.lacre (3.35 ton/acre). The non-irrigated pastureland reference area proposed by RAG Empire on the Eagle 5 & 9 mine is inferior to all the comparison values. Referring to Eagle 5 & 9 baseline "Disturbed Area Cover Data" Table 38 in the permit, the operator measured 29.1 % baseline vegetative cover. Permit page 2.05-33 states the required species diversity standard for reclamation success. If an azea is reclaimed to pastureland, species diversity, "will be satisfied by havingtwo-(2) species make up 70% relative percent composition in the reclaimed plant comments [sic]. No single species will contribute more than 50% of the relative composition." The results of the 2001 sampling of the proposed reference area "D" indicate that one species comprises 78.5% of the mean relative cover. The proposed reference area would not meet the success criteria for diversity. The Division is unable to approve this reference area in its current condition for the pastureland success criteria. The Division is concerned about the sampler's observation of the alfalfa seedlings. The sampler's observation ofnumerous alfalfa seedlings throughout the proposed reference area is consistent with recent