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8 <br />ground cover existing before redisturbance and shall be adequate to control erosion." <br />Thus, areas subject to the less stringent "cover only" success standard, are limited to <br />lands which were initially disturbed by mining operations prior to August 3, 1977, <br />subsequently abandoned, and then later redisturbed by remining operations. Lands <br />within the permit area disturbed prior to August 3, 1977, as .depicted on Map 29, <br />would qualify as "previously mined lands", if it can be demonstrated that they were <br />abandoned, and subsequently redisturbed after August 3, 1977. The "cover only" <br />success standazd would not apply to any alluvial valley floor irrigated haylands, <br />regardless of whether they qualify as "previously mined", due to the provisions of <br />3.03.1(3)(b) and 4.24, which require reestablishment of the essential hydrologic <br />functions and agricultural productivity of affected alluvial valley floors. <br />Please revise the sections of the permit application which address revegetation <br />success standazds, in accordance with the above discussion. ,vty azeas which qualify <br />as "previously mined" should be specifically delineated on Map 29, and <br />documentation supporting the designation should be submitted. <br />18. Irrigated haylands within the permit area aze referred to as. both "cropland" and <br />"pastureland" land use and vegetation types within the text of the application and on <br />various maps and tables. Since the irrigated fields aze appaze:ntiy harvested in most <br />years for hay, they would appear to more closely fit the cropland land use definition, <br />and should be consistently referenced as such. This distinction is significant with <br />respect to determinations of revegetation success, since cropland success is <br />determined solely on the basis of crop production, pursuant to Rule 4.15.9, whereas <br />pastureland is subject to the additional criteria of Rule 4.15.!3. <br />19. Five consecutive years of harvest records are presented for each of two irrigated <br />hayfields ("north" and "south"), and the application indicates that the average <br />production from this historic record will serve as the hayland success standard. The <br />Division assumes that the combined average produMion for both reference fields will <br />be used in wmparisons of revegetation success, but this should be specifically stated <br />in the application. If the intent was to use the records for the two fields sepazately, <br />this should be explained, and reclaimed azeas which would be compazed to each <br />specific reference 5eld would need to be delineated. <br />20. Page 2.05.4-24R of the application contains a commitment to monitor reclaimed sites <br />"every 2nd, 4th, 7th, and 9th years to determine revegetation success.. " Although at <br />least two areas (Williams Fork Strip Pit and Utah Tract) were reclaimed in the <br />1980's, no revegetation monitoring reports could be located in the Division files. <br />Please explain this discrepancy. If monitoring data is available, it needs to be <br />submitted to the Division. <br />