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re Mr. D.L. Damrau -2- December 29, 1983 In the land use section, TCC has found new information regarding the disturbed area. What was previously identified as rangeland in the original permit has been redesignated as croplands and pastureland in the new submittal. The changes are based on old aerial photographs. Before a decision can be made on whether the change is appropriate a representative from the Division will have to review the old photos. Additionally, an area must be actively managed in order to qualify as a pastureland. TCC has not provided a discussion of the active management methods undertaken on the newly designated pasturelands. Therefore, the photographs will have to be reviewed by the Division and TCC must provide a discussion of the management practices. The proposed change in land use designations is reflected in the re vegetation plan. TCC is proposing to seed with a cropland mix and a pastureland infix instead of the rangeland mix. These seed mixes cannot be approved until the concerns in the land use section are adequately addressed. ~In order to determine re vegetation success on croplands TCC is proposing to establish a reference area on an undisturbed site historically used for crop production. A discussion on the historical use of the proposed reference area should be provided as well as a schedule for establishing and sampling the area to provide baseline data. On page 4.15-8 it says that TCC plans to utilize two reference areas established in connection with Permit No. 79-177. Is this statement a typographical error or is the cropland reference area discussed above also in connection with Permit No. 79-177? TCC has requested a variance from the mulchiny requirement. This request is based on the applicant's observation that the annual weed cover is sufficient to control erosion. TCC has cited the results of a study established adjacent to the proposed permit area, Annual Grain Versus Volunteer Weed Biomass. More ~~ information on this study is requested. For instanr~e whqat size were the ~> plots, when were they sampled and what weed sp~c"~~'w~S~'~'"growing? Also, if an • area is seeded with a perennial mix in the fall what percentage of the early Vd.nan..~ spring growth are the annual weeds and the perennial mix? Further information .~,,, is needed before the Division can approve a variance from the mulching r>ti,lc~. requirement. "~ Elimination of the topsoil testing plan has also been requested. TCC states that since no nutrient deficiencies were detected on reclaimed sites adjacent to the proposed permit area and pre-mine soils information does not reveal any physical or chemical constraints, reconditioning or fertilizing is unnecessary. However, it has been documented that topsoil stockpiled longer than four to five years starts to lose its fertility (lJillia~ns and Singleton, a ~, 1980). Since the topsoil to be respread on the Foidel Creek disturbed area ~ will be stockpiled for a minimum of five years, representative samples of nitrate nitrogen;.~~ P~~ti^r~~ and potassium should be taken on the respread ~- topsoi 1. ~,,.~,,,;1~_ 1 rno ~ -~ n. G ~ ~. n ~ u - r P.u ~: „A,,:,, L, ~v~ . i ,,,~ .' 1-1_ ,,. G ~