REV98652

• Permit No: C1981008
• IBM Index Class Name: Revision
• Doc Date: 11/6/2006
• Doc Name: Draft Revew Memo
• From: Dan Mathews
• To: Mike Boulay
• Type & Sequence: TR54
• Media Type: D
• Archive: No

term successful establishment of pasture stands adapted to dryland conditions. OMLR had
suggested consideration of modified practices for dryland pasture establishment irrigation,
but WFC apparently has decided to eliminate the practice of irrigation for establishment
entirely, for dryland pasture plantings. The referenced text description on page (e)-11 was
properly deleted. However, there is a second brief reference to irrigation for establishment
of dryland pasture on amended page (e)-33. Please delete the reference to dryland
pasture irrigation for establishment in the first full paragraph on amended page
2.05.4(2)(e)-33.
See new comment 24 regarding the need for more detail on practices associated with
dryland pasture seedings, if irrigation for establishment will not be used.
12. OMLR had questioned whether water availability and water rights were sufficient to
ensure that irrigation would continue to be feasible on imgated pasture and cropland
following bond release, due in part to the fact that permit information indicated an increase
in irrigated acreage of 77 acres, following reclamation. Revised acreages for various land
use categories presented in the amended application indicate that the azea of irrigated land
(excluding drainage swales) is actually reduced by approximately 12 acres on the postmine
landscape, compared to premine. WFC indicated their belief was that "sufficient water is
available since WFC is able to use the water currently..." Please verify that there have
been no water rights transfers or other changes in recent years that would preclude
landowners from continuing to irrigate all of the irrigated reclamation acreage
following bond release.
13. OMLR had requested relatively minor clarification regarding the established standards
applicable to irrigated hay cropland and imgated pastureland. Subsequently, WFC became
concerned based on recent production records for reclaimed ftelds, that the approved 1.5
ton per acre standard for reclaimed irrigated pastureland might be excessive, for at least a
portion of the site, given the soil types present and other factors. As a result, the operator
contacted a number of local farmers and the NRCS Norwood Area Resource
Conservationist, and gathered support for a proposed reduction of the standard from 1.5
tons per acre to I.0 tons per acre for a portion of the irrigated pasture reclamation,
specifically the reclaimed irrigated pasture areas east of 2700 road.
This request to lower the standard has had the effect of re-opening the concept of the use of
technical standards to scrutiny. Technical standards have been approved for use at the
mine since initial permitting in the 1980's. There is a good synopsis of the reasons for use
of technical standards for imgated lands in the permit area on pages 2.04.10-17 and
2.04.10-18 of the PAP:
!t was Peabody's opinion and is WFC's opinion that adequate reclamation success
standards can be developed without the use of reference areas with the exception of
dryland pasture. Baseline sampling during the 1987 field season reconfirmed the
great variation in management objectives of individuals and the highly diverse
nature of the soils, geology, and ground and surface r+~ater regimes. In many cases
the management plans of operators (both within and adjacent to the study area)