2010-01-22_REVISION - C1981008 (2)

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C-1981-008 PR-06 PAR 22-Jan-2010 Page 20 of 26 57. Toward the end of narrative sub-section 2.0, there is reference to irrigated pasture being an important postmine vegetation type. A subsequent sentence states that irrigated pasture will be established on areas identified as hayland in the baseline vegetation studies. Please clarify to state that irrigated pasture will be established on areas identified as irrigated hayland and irrigated pasture in the baseline vegetation studies. Also, based on our understanding of the reclamation plan and site observations, we believe the postmining irrigated pastureland type (or Pastureland Irrigated Grass as it is referred to in most of the amended text), is actually more similar to the premining Pastureland Irrigated Hay sites, than it is to many of the premining Pastureland Irrigated Grass sites. The reclaimed irrigated lands are consistently irrigated, fertilized, and typically hayed. Soil salvage and replacement is conducted in a manner to restore the original site production potential, the seedmix contains alfalfa as well as grasses, and PR-6 amendments will allow for periodic interseeding for stand rejuvenation. The approved reference area incorporates adjustment factors to account for higher production potentials associated with deeper soils typically associated with hayland premining vegetation types. For these various reasons, please explain more fully in the text the nature of the postmining irrigated pasture type. Please amend the text as warranted. 58. There is a sentence fragment in the above referenced narrative section. The second sentence of the redline version reads: "In order to encourage `prompt establishment of vegetative cover and recovery of productivity levels compatible with the approved postmining land use' (4.15.1(2))". Please amend the text as warranted. 59. On the currently approved version of the Postmining Vegetation/Land Use Map Exhibit 2.05.4-5, there is a 6.73 acre parcel designated "Irrigated Farmland Alfalfa Hayland", located in the southeastern portion of the NH-2 area, apparently on Staats property. On the PR-6 proposed version of the map, the area has an IP (Pastureland Irrigated Grass) designation. Please provide explanation regarding reclamation history of this property and justification for the change from Alfalfa Hayland to Pastureland Irrigated Grass. Rule 2.06.6 Prime Farmlands 60. Rule 2.06.6(4) requires that, in order for the Division to approve a permit for the reclamation of prime farmland, a written finding must be made that the approved postmining land use will be cropland. A question that has not been resolved to the Division's satisfaction in the PR-6 application, is the extent of Prime Farmland on the 107.96 acre Morgan property in the permit area, located southwest of the corner of 2700 Road and BB Road. The area is dominated by Darvey-Bari soils, which qualify as Prime Farmland when irrigated with an adequate and dependable supply of water. Evidence