2009-04-07_REVISION - C1981008

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 4/7/2009
• Doc Name: Adequacy Review
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: TR58
• Email Name: MLT
• Media Type: D
• Archive: No

New Horizon Mine TR-58
Adequacy Review
07 April 2009
Page 2 of 4
There are no maps listed in the amended table of contents. We assume
that the two maps included with an earlier submittal [Map 2.05.4(2)(e)-1
and Map 2.05.4(2)(e)-2], both dated 10/27/08, were intended to be
included in the application. The maps provide the soil type delineations,
which are a critical component of the proposed reference area production
success standard. The maps should be listed in the table of contents.
The references to Attachment (e)-4 and (e)-5 on page 19J would appear to
be erroneous, as there are no such attachments. It would appear that the
references should be to Attachments (e)-2 and (e-3), respectively.
Please amend the table of contents, text, and map sections of the application
as appropriate.
2. Wording in the second paragraph of amended page (e)-19 Revegetation Standards
and Procedures for Testing for Successful Reclamation Irrigated Pasture Type,
could be misleading, and should be amended. "The success standard for WFC's
irrigated pasture will be based upon 1" cutting production only because we will
then be following the local practices and customs", would seem to imply that
success demonstration would be based on actual whole field harvest and
comparison to a standard based on 1St cutting whole field harvest.
Upon approval of TR-58, success demonstration would be based on statistically
adequate sampling and comparison to.an approved reference area. The following
wording would more clearly summarize the success demonstration approach for
Irrigated Pastureland as proposed in TR-58:
The success standard for WFC's irrigated pasture will involve
statistically adequate sample based comparison to an approved
reference area. The sampling will be conducted a single time
during late May-early June (immediately prior to I" cut harvest of
the reclaimed fields; with reference and reclaimed areas to be
sampled within a 7 day timeframe).
Please consider this concern and the suggested alternative language, and
revise the 2°a paragraph of amended page (e)-19, as appropriate.
3. Amended page (e)-19C contains the following statement in the first full paragraph
on the page:
For the reasons listed above, it is proposed that the fixed standards
for cover and production for all irrigated pasture in the permit
area be abandoned in favor of an irrigated pasture reference area.
For clarification, and to eliminate the possibility of differing interpretations that
could lead to misunderstanding and concern on the part of interested parties, we
would suggest the following wording
2