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2007-12-11_REVISION - C1981008
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2007-12-11_REVISION - C1981008
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Last modified
8/24/2016 3:19:16 PM
Creation date
1/30/2009 3:14:38 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
12/11/2007
Doc Name
Adequacy Review
From
DRMS
To
Western Fuels-Colorado
Type & Sequence
TR55
Media Type
D
Archive
No
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Mr. Ross Gubka, P.E. <br />Western Fuels-Colorado <br />December 11, 2007 <br />Page 4 <br />4.15.11(2)(c), in which the numerator parameters from the formula shown above <br />are reversed. <br />d) The statistical methodology associated with the two sample reverse null testing <br />procedure on page (e)-27 and continuing to the section headed "Irrigated Pasture <br />Type" on page (e)-28 is not applicable for Cropland success demonstration, since <br />reclaimed area production is compared to a technical standard rather than a <br />reference area. As such, two-sample testing is not appropriate, and the entirety of <br />the section presented under Method 4, beginning on page (e)-27 should be <br />deleted. <br />6. Discussion of the proposed reference area for the Irrigated Pasture Type is <br />presented on pages (e)-29 through (e)-34, location and boundaries are shown on <br />Map 3.02.2-10, and a detailed delineation of soil types and associated acreages <br />within the reference area is presented on Map 3.02.2-11. Cover and Production <br />data from the summer 2007 reference area sampling is presented in Appendix <br />2.05.4(2)(e)-5. Based on field observation and review of the information <br />presented, we believe the proposed reference area will be acceptable for use in <br />demonstrations of success for the Irrigated Pasture type at New Horizon. <br />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 <br />success demonstration for both production and cover would incorporate a soil <br />type based adjustment factor. We concur with the rationale presented with <br />respect to use of the adjustment factor procedure for production, but <br />demonstration that the adjustment factor procedure is warranted or appropriate for <br />cover has not been presented. The letter presented on page (e)-33 from MRCS, <br />provides production factors based on expected relative 'melds for the various soil <br />types present in the permit area. The NRCS analysis does not address the <br />parameter of vegetation cover associated with various soil types. Given the lack <br />of a basis for use of soil type adjustment factors for cover, reference area cover <br />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 <br />(e)-31, (e)-34, and elsewhere in the narrative if present, and revise the <br />narrative to clarify that reference area cover values will be used directly in <br />success comparisons, and the soil type based adjustment factor will be <br />employed for production success comparison. <br />b) A narrative description of the proposed reference area is provided under "New <br />Irrigated Pasture Reference Area" on page (e)-30. Please provide narrative <br />characterization of reference area vegetation (i.e. species composition, cover, <br />production, ecological condition), and the extent to which the vegetation is <br />representative of the irrigated pasture type in the permit area (prior to mine <br />disturbance). In addition, please address management activities including <br />irrigation method and application rate, livestock grazing plans and/or
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