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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 23 of 31 <br />48. Resolved. Use of the sterile hybrid Triticale "Quickguard" is specified in amended Subsection <br />6.1. Confirmation is provided that the Quickguard will be used as a stubble mulch, seeded <br />several months prior to seeding of the permanent Dryland Pasture seed mix. Appropriate time <br />frames are listed for seeding of the stubble mulch and the permanent mix. <br />49. In this item, the Division requested clarification regarding various details of interim <br />revegetation monitoring for reclaimed Irrigated Cropland, Irrigated Pastureland, and Dryland <br />Pastureland. Cropland monitoring is addressed in amended Subsection 5.6 of 2.05.4(2)(e), <br />while Irrigated Pastureland and Dryland Pastureland interim monitoring are addressed in <br />amended Subsection 7.0. We have the following comments: <br />a. For the cropland monitoring to be conducted in Year 5 and Year 8 of the liability period, the <br />intent of Items A and B appears to be that a qualified professional would assess based on <br />visual evaluation whether or not the cropland stand production appears to be comprised of at <br />least 75°,'/o desirable species. Items A and B of the subsection should be amended to make <br />this clear. However, the Division concludes that a higher quality standard should apply to <br />the prime farmland cropland, and that the relevant quality criteria should be that 85% of the <br />relative :production is comprised of alfalfa. This change should be made in the text of <br />Subsection 5.6 (see further comments regarding the quality standard for irrigated cropland, <br />in Item 5g, of this letter). Also, the word "test" in Item A should be replaced with <br />"evaluation" or "assessment". <br />b. Cropland monitoring Item C addresses bale weight measurement to assess hay production <br />per acre. The item should clarify that the estimated hay production would be reported in <br />pounds per acre, based on average bale weight, total bales in the subject field(s), and <br />acreage of the subject field(s). <br />c. For IP and DP interim monitoring to be conducted in Year 3 and Year 7, the intent of Items <br />A and B appears to be that a qualified professional would assess based on visual evaluation <br />whether or not the subject stand is progressing as desired, with respect to cover, and species <br />composition. Items A and B should be amended to make this clear. The word "test" in Item <br />A should be replaced with "evaluation" or "assessment". <br />d. Item C relevant to IP reclamation addresses bale weight measurement to assess hay <br />production per acre. The item should clarify that the estimated hay production would be <br />reported in pounds per acre, based on average bale weight, total bales in the subject field(s), <br />and acreage of the subject field(s). <br />50. Resolved. <br />Rule 2.05.5 Postminina Land Uses <br />51. WFC has adequately summarized all post mining vegetation/land use types in Section <br />2.05.4(2)(e) Subsection 2.0. In the Subsection 2.1 discussion for Cropland-Irrigated Alfalfa Hay <br />please delete the end of the second sentence that says, "as determined by the NRCS in 2008". <br />In the last sentence the reference should be to the discussion in Section 2.04.9 instead of 2.04.3. <br />52. In Subsection 3.0 WFC discusses the postmining land uses and identifies where landowner <br />parcels have been re-evaluated for the post mining land use. WFC has provided letters to the