2010-01-22_REVISION - C1981008 (2)

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C-1981-008 PR-06 PAR 22-Jan-2010 Page 16 of 26 would recommend that interim monitoring include both the visual assessment and a representative bale weight/count procedure on reclaimed and reference alfalfa fields. Please consider these recommendations and revise the narrative as warranted. 50. In subsection 12.1 of the NH-1 Mine Revegetation Plan, there is a misstatement within the text of Item 4 regarding allowable relative cover and production contribution of annual and biennial species. The last sentence of the subsection should state "An acceptable alternative is to delete all annual/biennial cover and production from the reference area AND THE RECLAIMED AREA prior to COVER AND PRODUCTION success comparison". Please add the bold all cap wording, which was erroneously left out of the text. Rule 2.05.5 Postmining Land Uses 51. In Section 2.05.4(2)(e) WFC is proposing the following post mine land use types: cropland-irrigated alfalfa hay (IC); Pastureland - irrigated grass (IP), Pastureland - irrigated swales (IPSW), Dryland pasture (DP), Rangeland-Undisturbed (R-U) and Potential Cropland (PC). (Revised Map 2.05.4-5 shows the postmining vegetation/landuse using the abbreviations.) These terms roughly coincide with the pre- mine land uses described in Section 2.04.3, but additional clarification is warranted. a) The Pastureland-Irrigated Grass definition (subsection 3.2) seems to be largely applicable to the irrigated pasture premining type, not the postmining type, given the references to "not as well managed as Pastureland Irrigated Hay", "poorer soils", and "do not yield as much vegetation". The definition needs to be revised to incorporate the concepts noted in Item 25. We suggest designating the postmining land use as "Reclaimed Irrigated Pastureland" to avoid confusion with the premining Pastureland Irrigated Grass type. b) The Dryland Pasture definition is incorrect. In PR-6 dryland pasture is not limited to "those areas that were previously sagebrush rangeland..." as proposed in the definition. Reclaimed Dryland Pasture is focused toward establishment of adapted dryland grasses and fortis, and the seedmix does not include sagebrush. The proposed definition does not make this clear, and could even be interpreted as implying that the reclaimed dryland pasture areas are intended to have "extensive shrub cover", which is obviously not the intent. Please amend the text as warranted. 52. Rule 2.05.5(1)(b) requires that the postmining land use plan be accompanied by a copy of comments concerning the proposed use by owners of record. Although the Division does not have authority to require landowners to provide comments for inclusion in the application, it was agreed that for PR-6, WFC would provide letters to the permit area