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C-A q � I W <br />United States Department of Agriculture n �� <br />4NRCS <br />Natural Room nee Conservetlan Service <br />An Boyd, Resource Conssrvaionlst <br />P. O. Box 29 <br />Norwood, CO 81423 <br />January 7, 2007 <br />To Whom it May Concern: <br />RECEIVED <br />,JAN 10 2008 <br />Division ot�R eclamation, <br />aft <br />W"ng <br />Jm.boydGca.usde.aov <br />970327- 4245-0FFICE <br />970327 -4247 -FAX <br />I was asked to comment on the Technical Revision No. 55, Section 2.05.4(2)(e) Revegetation for <br />the New Horizon #2 Mine of Western Fuels, Inc. After reading the Revision, the following are <br />my observations and comments intended to clarify what I believe are miscommunications and <br />inaccuracies: <br />Pages 5 & 6: <br />It was stated that "irrigated hayland and pastureland are very similar in composition in many <br />cases and may be used interchangeable depending on the operator's needs." This may be true for <br />some fields that are managed for grass or grass/alfalfa hay, and then also grazed by livestock at <br />various times of the year. But there are other instances, quite common, when crop fields are <br />managed solely as hayland, particularly alfalfa hay. This latter condition usually occurs on the <br />better soils, and relies on a high level of management by the operator - <br />This Revision Document repeatedly uses the terms cropland, hayland, and pastureland almost <br />interchangeably and therefore fails to make the appropriate distinctions between these three <br />agricultural land uses. The following definitions and discussion are intended to clarify these <br />terms and encourage accurate use of them. <br />Cropland: Abroad term used to identify land which produces an agricultural commodity. But <br />for United States Department of Agricultural purposes, it is more specifically used for land that <br />is managed intensively with tillage and other cultural practices to produce commodities such as <br />vegetables, grains, hay, silage, etc. It is considered distinct from pastureland in that periodic re- <br />seeding of a crop is usually necessary to sustain a high level of production. Occasionally, crop <br />aftermath or residue may be grazed after the crop is harvested. <br />Hayiand: A term used to describe land that is used primarily to produce livestock forage that is <br />mechanically harvested and stored for later use. It is considered cropland, and a high level of <br />management (fertilizing, irrigating, Pest control, etc -), with periodic re- seeding, is usually <br />necessary to sustain production. As with other cropland, haYland may be grazed at various times <br />of the year depending on the forage grown and the needs of the producer. The common types of <br />hay grown in western Colorado include alfalfa, alfalfa/grass mix, and grass (introduced and/or <br />native species) <br />The Natural Ptavouma Corwaredbn Service wants In yar4reMMP with 00 Aff0dCW People An Equal Opportunity Provider and Employer - <br />to conserve and sustain natural resouoes an priwde Wnds. <br />