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BaVYl? NU, 1 Mini <br />TR-51 ??? AR <br />1 o-I?ov-??a9 <br />Page 2 of ? <br />DR1V?: .fin order ?o c?ar?f? t?? ?i??i?i?r period, p??ase in??u?e i? ??is ?ec??o? ?? <br />fol?o?i? s?a?ee?t? quoted from ??e ?. X5.9: "'rep produc?io? w??? ?o? be ca?siered <br />prior to ?y?r ??? o ?e ?i??i?it? period. ?, <br />BRL; statement ? added to page x.05 -?7. <br />DR: item reso???d; ?o?urt?er? response is necessary. <br />4. DRN?: BRL proposes to measure herbaceous production on the reclaimed cropland and <br />compare the reclaimed production to a technical standard.. The proposed technical <br />standard replaces the currently approved reference area. Rule 4.15.71}?d}iii} allows the <br />use of standards by reference to technical dacun?ents of the U,, Department of <br />agriculture, including the NR??, However, these documents must be approved by the <br />Division and the I?lrectar of the office of surface Mining. The ?ivislon w111 be <br />proposing a rule an?ndn?nt that w111 rerr?ove the requirement for Director approval, to be <br />consistent with Federal rule changes. This rule change is in the preliminary phases clang <br />with many other proposed rule revisions. It will be reviewed by many different parties, <br />and it may be a year or two before rule amendments are Finalized, BRLL may want to <br />maintain the reference area for now and submit a technical revision l'or use of a technical <br />standard aver a decision on the proposed rule revision is finalized. <br />BRL did not submit docuentat??n of the proposed technical standard. A conversation <br />with Robbie-Baird-Le'Valley from the U Extension service is referenced; however, <br />there i no supporting dacurrlentatian. The technical standard recommendation must be <br />on letterhead. <br />The proposed standard of 15a? tor?s?acre far the first cutting is used an the expected <br />yield from irrigated pasture. Does this tale into account the fact that the site has been <br />disturbed and will only have `available' topsoil redistributed? <br />BRL; A reference area was selected in lieu of the technical standard. Bowie may revisit <br />a technical Standard in the future, The location of the reference area iS shown on new <br />Map 15, Irrigated rapland Reference Area. Dacumentatian of right of entry to the <br />reference area is also enclosed {far Exhibit 14}. <br />DR; ??era reso??ed; no further response rs necessary. <br />5. ?R? The Irrigated Gayland -? sampling Methods sectXOn on pages ?.??-2S describes <br />the method proposed for sampling and evaluating the production of cropland at the <br />Laadaut Facility. The proposed n?ethvdolog? i acceptable. <br />?R; 1Vo response ?s necessary,