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G. S. Bacon Page 2 November 26, 1996 15, 1996. This was discussed with Dan Mathews of the DMG by telephone on October 29, 1996. It was agreed during this phone conversation that the best way to derive a standard for the reclaimed hayland disturbed area would be via Rule 4.15.7(d)(ii). The most obvious source for dependable production information would be from Soil Conservation Service (now Natural Resources Conservation Service) information, especially that information within the 1985 publication "Soil Survey of Rifle Area Colorado: Parts of Garfield and Mesa Counties". By overlaying Figure 3.5-2 (Soils Map) on Figure 3.6-2 (Vegetation Map), it appears that the irrigated hayland community in the disturbed area falls within the Heldt Silty Clay (6 to 12% slope) and the Nrhill Storry Loam (6 to 25% slope) soil designations of the approved permit application. These designations correspond to soil types 30 and 47 on the SCS Soil Survey map 12, identified as Heldt clay loarn, 6 to 12% slope and Ndmill channery loam, 6 to 25 percent slopes respectively in the body of the Soil Survey document (see page 92, Table 4). Table 6, titled Rangeland Productivity and Characteristic Plant Communities. on pages 97 through 102 of the Soil Survey indicates that the expected annual total production (which includes shmub production) in a normal year would be 900 pounds per acre for the Heldt soil type and 800 pounds per acre for the Ndmill soil type. NCIG is prepared to accept a production success standard of 900 pounds per acre to apply to the Irrigated Hayland community. This standard is acceptable despite being the higher of the two applicable quantities and despite being a total and not an herbaceous production value. Page 4-62a has been change to reflect the proposed standard. 7. No response requved. 8a. The woody stem density sampling methodology will be as follows: Woody stem density will be estimated using elongated quadrats. Quadrats will be 2i meters by 2 meters, or 50 square meters in size. The number of woody stem that are rooted within the quadrats will be counted. Samples will be collected until sample adequacy is attained. This paragraph has been added on page 4-62c. 8b) As noted by the Division, revised page 4-62 contains the following paragraph: "It is not anticipated that the sampling methods used during the baseline study will be repeated when the operator determines whether revegetation has been successful. The methods which are outlined below are suggested instead. The methodology reflects the recently accepted DMG Bond Release Guideline (Guideline Re ardina Selected Coal Mine Bond Release Issues. April 18. 1995). It is understood that the operator may make changes to this suggested methodology in coordination with DMG prior to the beginning of sampling without having to revise the present permit document."