2010-01-22_REVISION - C1981008 (2)

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C-1981-008 PR-06 PAR 22-Jan-2010 Page 17 of 26 landowners requesting their comments on the proposed postmining land uses, and that copies of the letters would be included in the application. In Attachment 2.05.4(2)(e)-8 "Correspondence with Landowners on Post-mining Land Use Changes", the operator has included letters to WFC, Mr. and Mrs. Frank Morgan, Mr. and Mrs. Bud Benson, and Mr. Harry Curtis Lloyd. These letters represent only the subset of landowners with holdings west of 2700 Road. If landowner letters have been provided to or comments have been submitted by landowners with holdings in the remainder of the permit area, please provide documentation (or reference the permit sections where such documentation is provided). Otherwise, please prepare and send appropriate letters to the remaining landowners, and provide copies for inclusion in Attachment 2.05.4(2)(e)-8. 53. The currently approved version of Map Exhibit 2.05.4-5 "Postmining Vegetation/Land Use Map" includes depiction of existing and planned irrigation infrastructure (laterals, ditches, pipes, sprinklers, etc.). The PR-6 version of the same map does not include this information. Given the necessity of such structures for the reclamation plan and the postmining land use, please amend the map or provide a supplemental map to depict the irrigation structures, with notation to distinguish between facilities proposed as permanent and facilities that are temporary for use during the liability period. The base map for depiction of the irrigation infrastructure should include topographic contours as depicted on Map 2.05.4-1 "Existing & Projected Reclamation Contours New Horizon #2 Mine". 54. In association with review of a prior permitting action, the Division had noted that the proposed acreage of irrigated land postmining in the NH-2 permit area exceeded the acreage of premining irrigated land by approximately 70 acres, and requested that WFC assess the status of irrigation water availability, to ensure that mined lands reclaimed to irrigated pasture could continue to be irrigated after bond release. WFC subsequently evaluated the extent of acreage that could be properly irrigated to maintain the irrigated stands on the permit area following bond release, based on the acreages and water shares owned by permit area landowners. Based in part on the results of this evaluation, WFC has proposed a revised revegetation/postmining land use plan for PR-6, reflected in the amended Map 2.05.4-5. In the PR-6 application, the postmining irrigated acreage is substantially less than the premising irrigated acreage (309 acres vs. 556 acres approximately, excluding drainage swales, as calculated by the Division). A portion of the postmining reduction in irrigated land is due to WFC ownership of approximately 70 acres in the northwest portion of the NH-2 permit area and approximately 29 acres in the southeast portion of the NH-2 area. Both of these areas were predominantly irrigated land prior to mining, which WFC proposes in PR-6 to reclaim to dryland pasture. Based on our initial review we believe further explanation and clarification is necessary to explain the proposed increase in dryland pasture acreage. WFC must demonstrate that the extent of irrigated lands proposed does represent prudent management, and that the