2009-07-30_REVISION - C1981008 - Laserfiche WebLink

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reflects campositianai differences between the two areas, ar whether there may have been a significant die-off of grass plants due to drought, between the two sampling years, which accounts for the dramatically reduced grass production in the ?gDS data. 1Ne recommend that the operator and Division undertake a joint, qualitative assessment of the two reference areas. Dryland pasture reclamation is generally directed toward the establishment of grass dominated stands. If there appears to be a qualitative di#ferenc? with respect to perennial grass abundance, production, and cover between the two areas, reversion to use of the combined reference area may be warranted. New Horizon ? Revegetation ?ect?on ?.D5.4(???e}} 8. T1?ere is same confusion in the text of the Revegetatian section and in the Postmine VegetationlLand Use I?ap x,05.4-?, with respect to designationldelineatian of potmining land uses versus pastmining vegetation types including crap types and pasture types}. Clarifications are requested, similar to the clarifications requested previously in this letter, with respect to premine land use versus vegetation type delineations. vVe Hate that mare intensive management practices are specifically allowed under Di?IG regulations for lands designated as alfalfa hay ar grass hay cropland, as compared to pastureland. specifically, for these perennial cropland types, Rule 4.15,??d} allows periodic sfar?d renewal r'rrcluding rr?a?or frflage and reseedirrg...when such practices are corasisfer?# with norrnaf or prudent r?arragernenf ?n the raglan ar?d coufd reasonably be expec#ed to occur alder final band release. In accordance with Rule 1.04 land use definitions, the primary postmining land uses within the permit area would appear to be "Cropland", "Pastureland", and "Rangeland", Crop types within the Cropland Land Use areas would appear to include irrigated alfalfa hayland ?eedmix 7}, irrigated grass hayland ?eedmix 5?, and possibly some or all of the areas currently designated irrigated pasture-?rell drained balsa eedmix 5}. The distinction between reclaimed areas currently identified as irrigated grass hayland and irrigated pasture i Hat clear. If there are specific reciarnation plan distinctions or management practice differences between postmine eedmix 5 areas designs#ed irrigated grass hayland compared to areas designated irrigated pasture, these differences shoutd be explained. Even'rfthere are reclamation or management distinctions between the two types, if it is a reasonable expectation that the irrigated pasture fields would be regularly used for hay production following pond release, cropland would likely be the appropriate land use designation. Forage or pasture types within the Pastureland land use classification would appear to include irrigated pasture?pvorly drained sites ?eedmix ?},and possibly some or ai# of the areas designated irrigated pasture---well drained ?eedmix 5}. The remaining type within the Pastureland land use classification is dryland pasture ?eedmix 8?. Please amend the "Potminir?g Land Use" narrative an pages ? and ?, to be consistent with the land use designations of x.04. Also, please amend Map ?.05.?-5 to eliminate ambiguities. The current map includes categories of dryland pasture, irrigated pasture, irrigated hayland, irrigated alfalfa hayland, and rangeland. These categories don't directly match up with postminir?g vegetation types ar?d seedmixes ?lted later In the tax#, l~o? example, the map type "irrigated hayland" apparently corresponds to the vegetation typelseedmix "irrigated grass hayland", but this should be clarified, Also, while rangeland types are depicted on the rr?ap, there is no rangeland seedmix listed, and Table lists no rangeland pvstmine acreage. This should be explained, and the map amended if warranted. 4