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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 17 of 31 <br />44. WFC has reorganized the permit to provide separate discussions of the revegetation methods for <br />each postmining land use in Section 2.05.4(2)(e). <br />Subsection 4.0 Revegetation - Reclaimed Irrigated Pastureland (IP) <br />a. In Subsection 4.1 Topsoil Replacement - General Comments, there are several <br />discrepancies with the text in Section 4.4 on Seeding Procedures, including latest date for <br />seeding (July 15 in Section 4.1 versus June 15 in 4.4), and seeding rate for oats or barley <br />cover crop (25# per acre in 4. 1, versus 40# per acre in 4.4). Please confirm and document <br />the appropriate latest date for IP seeding during the growing season, and the appropriate <br />companion crop seeding rate with NRCS. We are aware that NRCS has reviewed and <br />concurred with Subsection 4.4 narrative, but in a letter of January 7, 2007, their <br />recommendation for companion crop seeding rate was 20# per acre. The Division suggests <br />that the general comments in Section 4.1 pertaining to seeding (paragraph 1 after the 3rd <br />sentence, all of paragraph 2, and all of the final paragraph of the section) be deleted to avoid <br />confusion. <br />b. Please remove all NRCS documents from the body of the permit text, place the entirety of <br />the letters in Attachment 2.05.4 (2)(e)-11, and reference the letter and attachment in the <br />permit text. <br />c. The last paragraph of Subsection 4.4 on interseeding duplicates the liability period <br />management discussion in Subsection 4.6 and duplicates the NRCS October 17, 2007 letter. <br />This paragraph should be deleted from Subsection 4.4 and left in Subsection 4.6. <br />d. Subsection 4.5 discusses the Irrigated Pastureland Revegetation Success Criteria and <br />Success Demonstration. <br />i. In the first paragraph WFC references annual fertilization of reclaimed irrigated <br />pasturelands in both the 3rd and 41h sentences. This contradicts several other sections. <br />Please replace "annual" fertilization with "scheduled" fertilization. <br />ii. The reference to Table 2.05.4(2)(e)-2 in the second paragraph is incorrect. Table <br />2.05.4(2)(e)-2 pertains to the Irrigated Pastureland Reference Area; correct reference <br />would appear to be Table 2.05.4(2)(e)-4. Please correct. <br />iii. The sentence in italics regarding 1987 Peabody measurements is out of context, but <br />apparently refers to fields for which harvest production figures are reported in Table <br />2.05.4(2)(e)-4. The sentence needs to be deleted or inserted earlier in the paragraph, <br />immediately following reference to the table to which it applies, if it is retained. <br />Further, the phrase "these measurements were accurately measured" does not make <br />sense, please delete the sentence or reword it for clarity if it is retained. <br />iv. The Division recommends that the detailed discussion regarding justifications for the <br />change from a technical standard to a reference area for IP production success <br />demonstration be consolidated and summarized. The change was previously <br />approved, and it is not necessary to retain all of the detailed itemized justifications in <br />the section narrative. It would be sufficient to state that the change was approved in <br />2009 with TR-58, based on data and justification provided in the revision submittal <br />(note that the reference to October 2008 approval of TR-58 is incorrect and should be <br />revised). <br />V. The heading for Subsection 4.5.1 "Reclaimed Irrigated Pastureland Soil Analysis" is <br />misleading. Please change the heading to "Irrigated Pastureland Reference Area Soil <br />Production Factors". The narrative in the first three paragraphs below the subsection