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Bowie No. 1 Mine <br />TR-51 PAR <br />29-Jan-2009 <br />Page 2 of 3 <br />Please specify the water right(s) that will be used to irrigate the cropland areas at <br />the Loadout Facility, or direct the Division to the location of the information, if it <br />may already be found in the Permit. <br />3. The last paragraph on Page 2.05-27describes measures proposed to be used to <br />determine the success of revegetation. Portions of Rule 4.15.9 are transcribed, but the <br />subject of the period of liability is ambiguous. <br />In order to clarify the liability period, please include in this section the following <br />statement, quoted from Rule 4.15.9: "Crop production will not be considered prior <br />to year nine of the liability period. " <br />4. In the section on success of revegetation, Bowie is proposing to measure herbaceous <br />production on the reclaimed cropland and compare the reclaimed production to a <br />technical standard. The proposed technical standard replaces the currently approved <br />reference area. Rule 4.15.7(1)(d)(ii) allows the use of standards by reference to <br />technical documents of the U.S. Department of Agriculture, including the NRCS. <br />However, these documents must be approved by the Division and the Director of the <br />Office of Surface Mining. The Division will be proposing a rule amendment that will <br />remove the requirement for Director approval to be consistent with Federal rule <br />changes. This rule change is in the preliminary phases along with many other <br />proposed rule revisions. It will be reviewed by many different parties; and it may be a <br />year or two before rule amendments are finalized. BRLLC may want to maintain the <br />reference area for now and submit a technical revision for use of a technical standard <br />after a decision on the proposed rule revision is finalized. <br />Bowie's did not submit documentation of the proposed technical standard. A <br />conversation with Robbie-Baird-LeValley from the CSU Extension Service is <br />referenced, however there is no supporting documentation. The technical standard <br />recommendation must be on letterhead. <br />The proposed standard of 1500 tons/acre for the first cutting is based on the expected <br />yield from irrigated pasture. Does this take into account the fact that the site has been <br />disturbed and will only have `available' topsoil redistributed? <br />5. The Irrigated Hayland - Sampling Methods section on pages 2.05-28 describes the <br />method proposed for sampling and evaluating the production of Cropland at the <br />Loadout Facility. The proposed methodology is acceptable. <br />6. Page 2.05-29 describes the soil testing plan. BRLLC says that the regraded area will <br />be surveyed for the presence of large rocks. The Division recommends anything <br />larger than cobble (20 cm) be removed as larger fragments may harm a mower if the <br />field is to be hayed. Please define what constitutes a large rock and revise the text <br />accordingly.