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Marcia Talvitie, P.E. -2- October 13, 2009 <br />clarify the liability period, please include in this section the following statement, <br />quoted from Rule 4.15.9: "Crop production will not be considered prior to year <br />nine of the liability period." <br />BRL - The statement was added to page 2.05-27. <br />4. DRMS - In the section on success of revegetation, Bowie is proposing to <br />measure herbaceous production on the reclaimed cropland and compare the <br />reclaimed production to a technical standard. The proposed technical standard <br />replaces the currently approved reference area. Rule 4.15.7(1)(d)(ii) allows the <br />use of standards by reference to technical documents of the U.S. Department of <br />Agriculture, including the NRCS. However, these documents must be approved <br />by the Division and the Director of the Office of Surface Mining. The Division will <br />be proposing a rule amendment that will remove the requirement for Director <br />approval to be consistent with Federal rule changes. This rule change is in the <br />preliminary phases along with many other proposed rule revisions. It will be <br />reviewed by many different parties; and it may be a year or two before rule <br />amendments are finalized. BRLLC may want to maintain the reference area for <br />now and submit a technical revision for use of a technical standard after a <br />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 <br />standard recommendation must be on letterhead. <br />The proposed standard of 1500 tons/acre for the first cutting is based on the <br />expected yield from irrigated pasture. Does this take into account the fact that the <br />site has been disturbed and will only have `available' topsoil redistributed? <br />BRL - A reference area was selected in lieu of the technical standard. Bowie <br />may revisit a technical standard in the future. The location of the reference area <br />is shown on new Map 15, Irrigated Cropland Reference Area. Documentation of <br />right of entry to the reference area is also enclosed. <br />5. DRMS - The Irrigated Hayland - Sampling Methods section on pages 2.05-28 <br />describes the method proposed for sampling and evaluating the production of <br />Cropland at the Loadout Facility. The proposed methodology is acceptable. <br />BRL - No response required. <br />6. DRMS - Page 2.05-29 describes the soil testing plan. BRLLC says that the <br />regraded area will be surveyed for the presence of large rocks. The Division <br />recommends anything larger than cobble (20 cm) be removed as larger <br />fragments may harm a mower if the field is to be hayed. Please define what <br />constitutes a large rock and revise the text accordingly.