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REV98652
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REV98652
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Last modified
8/25/2016 3:22:42 AM
Creation date
11/22/2007 12:20:14 AM
Metadata
Fields
Template:
DRMS Permit Index
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
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in the reference area, reverse null testing would employ Satterthwaite <br />corrected two sample t-testing. <br />18. OMLR noted that the mid summer timeframe for sampling specified in the application <br />might be overly restrictive, given the growth patterns of the introduced cool season pasture <br />grasses and legumes utilized in the New Horizon Reclamation. The section was properly <br />revised. Item Resolved. <br />New Review Comments <br />19. The Tab 22 Table of Contents does not correspond to the page numbers of the amended <br />Tab 22 narrative, tables, and appendices. Please amend the Table of Contents section as <br />appropriate. <br />20. Table 22-5 indicates that the production standazd for NH-1 dryland pasture reclamation is <br />to be based on comparison to a technical standard of 500 pounds per acre. For the same <br />basic reason discussed above under Comment 13, use of a technical standazd for <br />production is problematic. A dryland pasture reference area has been established for <br />demonstration of successful cover establishment, and we believe it would be appropriate to <br />designate the same reference azea to be used as the method for demonstration of dryland <br />pasture production success comparison. Please amend Table 22-5 to specify use of the <br />dryland pasture reference area for NH-1 production success demonstration. <br />21. There currently are no species diversity success criteria applicable to the pastureland or <br />cropland types within the NH-1 or NH-2 mine azeas. Diversity requirements had been <br />waived in the past, due to the focus on establishment of a relatively small number of <br />improved pasture grasses and legumes. OMLR believes it is true that traditional diversity <br />criteria applied to rangeland and wildlife habitat reclamation areas are not appropriate for <br />New Horizon agricultural lands. However, as discussed at the mine site meeting on May <br />2, 2006, involving NRCS, OMLR, and WFC representatives, criteria to ensure that <br />reclaimed azea vegetation is of acceptable quality (i.e. primazily composed of desirable <br />species) is warranted. An example of the type of criteria that might be appropriate would <br />be: "At least 75% of the relative cover or relative production will be comprised of seeded <br />species or species of compazable quality as livestock forage, and no more than 3% relative <br />cover or relative production will be comprised of county listed noxious species". Because <br />cropland areas might otherwise be harvested and not sampled, sampling of cropland areas <br />to make the relevant demonstration would be necessary. For the purposes of the "quality" <br />demonstration, species composition percentages based on a statistically adequate cover or <br />production sample, or minimum of 30 observations, would be acceptable. Finally, because <br />Jim Boyd of NRCS brought up this concern at the May meeting, please contact him in <br />regazd to development of appropriate "quality" standazd or standards. <br />Please amend the revegetation success demonstration success sections of the <br />application to inlcude species composition quality criteria for NH-1 and NH-2 <br />dryland pasture, irrigated pasture, and irrigated cropland vegetation types. <br />
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