2010-05-25_REVISION - C1981008 (28)

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UMted States Deipartnmat of Agriculture 4NKS calantam sWAN ..Nay 804 Rawft Carwaft t P.O.Omn NOW04 Co 014x3 January 7, 20W To Whom it May Conan: I. Ow I was asked to comment on the Technical Revision No. 55, Section 105.4(2xe) Ravegetation for the New Harmon #2 Mine of Western Fuels, Inc. After reading the Revision, the following are my observations and continents intended to clarify what I believe are misooamwnications and inaccuracies: Pages 5 dt 6: It was stated that "irrigated hayland and pastureland are very similar in composition in many cases and may be used interchangeable depending on the operator's needs." This may be true for some fields that are managed for grass or grass/alfelfa hay, and then also grazed by livestock at various times of the year But there are other instances, quite won, when crop fields are managed solely as hayland, particularly alfalfa hay. This latter condition usually occurs on the better soils, and relies on a high level of management by the operator. This Revision Document repeatedly uses the terms cropland, hayland, and pastureland almost interchangeably and therefore fails to make the appropriate distinctions between these three agricultural land uses. The following definitions and discussion are intended to cIW* these tams and encourage accurate use of them Cropland: A broad tam used to identify land which produces an agricultural commodity. But for United States Department of Agricultural purposes, it is more specifically used for land that is managed intensively with tillage and other cultural practices to produce commodities such as vegetab lam, hay, silage, etc. It is considered distinct from pastureland in that periodic re- seeding of a crop is usually necessary to sustain a high level of production.. Occasionally, crop aftermath or residue may be grazed after the crop is harvested. Hayland: A term used to describe land that is used peima: ly to produce livestock forage that is mechanically harvested and stored for later use. It a considered cropland, and a high level of management (fertilizing, irrigating, pest control, etc.), with periodic re- seeding, is usually necessary to sustain production. As with other cropland, hayland may be grazed at various times of the year depending on the forage grown and the needs of the producer. The common types of hay grown in western Colorado include alfalfa, alfalfa/grass mix, and grass (introduced and/or native species). TIM NtMrtl Ihtamn QarMMVdat Sx+b watt b /rYrnli� Milt M AMWI= Poo* `a�Mww ati tMIWt tteiai t,tMtl7tt m MIwEt IM�dt. M ErMI e>NMrtrq� RwMNr zed aM�Mrytr. PR -06 May 2010 2.05.4(2)(e) - 21