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changed weekly. Whis accarre even on hands where Peabody had ? reasonable <br />bevel o control, drop rotatiar?s or pasture acrd hayland renovation cold easily <br />eliminate or change the nat?rre of a reference area at the time a? f ???d r???ase <br />evaluations. Personal n?anagen?ent objectives and methods are highly variable for <br />t1?e various landowners ar lessees. lrria?ior? water anagenzen?, fertilization <br />programs ??f any, harvest period, haylpasture rrranage?nent, cropping, and grazing <br />management were dr? ferer?t for ?ear?y ??? lar?dawners cor?t??td ??te end result of <br />the above is a situation of no guarantees, guarantees of long terra and somewhat <br />consistent n?anagen?ent are a critical element that m?cst be reasonably assured <br />when ?csir? reference areas. Wherefore, Peabody has developed alternate <br />reclamation standards as a?Iowed for under ?, ? 5.7??? (d? of the Regulations <br />The ?M?,R, in past permitting decisions for New Horizon, had found these arguments far <br />the use of technical standards to be persuasive, and has approved technical standards in <br />lieu ofreference areas. The productivr? standards for irrigated cropland and irrigated <br />pastureland were previously lowered via revision, based largely on documentation <br />consisting of letters from the NR? Area Resource conservationist and three local <br />farmers in l9?$, attesting to the fact that the original standards were excessive, and not <br />reflective of local soil conditions and agricultural practices, <br />Within the current TR-?4, the operator is proposing to further lower the production <br />standard for ?rrlated pasturelands within a portion of the permit area. A letter signed by <br />two of the landowners in the area east of ?7?D road was provided in support of the <br />proposed change, along with a letter from the NR? Resource conservationist, Jim Boyd, <br />supporting a proposed standard of "one tonlacre of baled hay in dune first cutting}". <br />According to a letter provided by kris ubka of wFC, two other landowners within the <br />reclaimed area east of 27?? Road were contacted, and "agreed in prlnclple to the <br />reasoning of the standards change", but would not sign the letter supporting the change <br />due to concerns "which have nothing to do with the standards change". <br />In the letters signed by Jim Boyd and the two local landowners, prirriry reasons cited for <br />the proposed reduction are predominance of shallow sail types, generally southerly aspect, <br />and the fact that irrigation water i often not made available by the ditch company as early <br />in the growing season as would be desirable, J1rri Boyd notes in his letter that the call <br />types are not typically Irrigated in the Nucla area, and s a result production records are <br />limited for the types under irrigated conditions. Based on previous discussion with 1VIr. <br />Boyd, there apparently is no published information regarding typical production levels <br />that could be expected under irrigated conditions far any of the soil types in the permit <br />area, because the lolls are rarely ?rrlgated except, apparently iii the irrimediate vicinity of <br />the New ?Iarizon Mine}? <br />C?nfortunately, given the rather unique set of environmental and land use conditions in the <br />permit area vicinity, Rule 4.15.7}?d? does not iri actuality authorize success standards for <br />vegetative cover ar herbaceous productivity to be based on technical standards, unless <br />documents upon which the standards are based are approved by the director of O1V[. The <br />or?l? copar?son methods authorised by the regulations that would. be applicable to the <br />