2010-05-25_REVISION - C1981008 (28)

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these measurements were accurately measured by Peabody in 1987 for fields that contained alfalfa hay and the Yield was only 0 82 tons per acre Prior toTR -58 of 2008, the production standard fori tum asture /and was 1.50 tons per acre. Considerable evidence shows that this standard is too high. See below. 1) The information from Table 2.05.4(2)(e) -4, which shows that the yields for 1987 for irrigated hay were only (1639lbs) 0.82 tons peracre. Although this is only one year of information, it is still carefully collected data that is not based on visual estimates. 2) The fact that most irrigated fields contain alfalfa which is a high production plant, but as years go in a given field, the percentage of alfalfa dwindles, thus lowering the yields. Since the bond release period is 10 years, the mine is handicapped since the sampling can only occur in the 9' and 1(Y year after seeding. 3) The general aspect of the field is south facing which robs the natural moisture from the land to a far greater degree than a flat or north facing slope. This is crucial in periods when the irrigation water is not running. 5�) The soils in the permit area east of 2700 Road are generally poor and are not irrigated anywhere else in Montrose County nor the surrounding counties. These soils are Progresso, Bond, Travessilla and Pinon. See Map 2.04.9 Soil Baseline Map. As seen in Attachment 2.04.9 -3 Taxonomic Unit Descriptions, all of these soils are thin and rocky, are generally found in New Mexico and Arizona in very dry areas, are alkaline and are primarily used for rangeland, not irrigated fields. 5O The NRCS representative of the area, Jim Boyd, has years of experience with i Reclaimed Imgated pastures Pasturelands in the area and confirms that the conditions forthe reclaimed area east of 2700 Road do not warrant a yield above 1.0 tons per acre. See his letter on the following PR -06 May 2010 2.05.4(2)(e) - 48