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area sampling is presented in Appendix 2.05.4(2)(e)-5. Based on field observation and <br />review of the information presented, we believe the proposed reference area will be <br />acceptable for use in demonstrations of success for the Irrigated Pasture type at New <br />Horizon. However, we have a number of questions regarding the details of the information <br />provided, including plans for use and management of the reference area. <br />a) One issue of concern is that narrative beginning on page (e)-31 indicates that success <br />demonstration for both production and cover would incorporate a soil type based <br />adjustment factor. We concur with the rationale presented with respect to use of the <br />adjustment factor procedure for production, but demonstration that the adjustment factor <br />procedure is warranted or appropriate for cover has not been presented. The letter <br />presented on page (e)-33 from NRCS, provides production factors based on expected <br />relative iy elds for the various soil types present in the permit area. The NRCS analysis <br />does not address the parameter of vegetation cover associated with various soil types. <br />Given the lack of a basis for use of soil type adjustment factors for cover, reference area <br />cover values should be used directly in comparisons of revegetation success, with no <br />adjustment. Please delete references to use of adjusted cover values on page (e)-31, <br />(e)-34, and elsewhere in the narrative if present, and revise the narrative to clarify <br />that reference area cover values will be used directly in success comparisons, and the <br />soil type based adjustment factor will be employed for production success <br />comparison. <br />b) A narrative description of the proposed reference area is provided under "New Irrigated <br />Pasture Reference Area" on page (e)-30. Please provide narrative characterization of <br />reference area vegetation (i.e. species composition, cover, production, ecological <br />condition), and the extent to which the vegetation is representative of the irrigated <br />pasture type in the permit area (prior to mine disturbance). In addition, please <br />address management activities including irrigation method and application rate, <br />livestock grazing plans and/or haying, fertilization, etc., that will be conducted to <br />comply with Rules 4.15.7(3)(d) "management in accordance with approved <br />postmining land use" and 4.15.7(3)(f) "management consistent with reclaimed area <br />during bond release sample years". <br />7. The procedure for calculating an acreage weighted soil type based adjustment factor for a <br />reclaimed block is described in the narrative on amended page (e)-31 and calculation of the <br />weighted average adjustment factor for the reference area is presented on the same page, in <br />Table (e)-3. The procedure for using a reclaimed area adjustment factor to modify the <br />reference area (production) value is also described, but the description of the procedure <br />does not completely reflect our understanding of how the factor would be used, and does <br />not appear to be entirely correct. Please consider the following language to replace the <br />final sentence on page (e)-31: <br />This weighted average adjustment factor is then divided by the reference <br />area weighted average adjustment factor (1. 022), and the resulting value <br />is multiplied by the reference area production sample mean to obtain the <br />production standard for that particular reclaimed block. For the purpose <br />4