2010-08-25_REVISION - C1981008

• Permit No: C1981008
• IBM Index Class Name: Revision
• Doc Date: 8/25/2010
• Doc Name: Adequacy Review No. 5
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: PR6
• Email Name: MLT
• Email Name: SB1
• Media Type: D
• Archive: No

C-1981-008
PR -06 AR#f5
August 25, 2010
Page 17 of 26
1. The Division requested certain clarifications to the Dryland Pasture fertilization management
plan presented in Subsection 6.5.2. The plan was modified to an extent, but we note that
there is an erroneous reference to irrigated cropland in the first paragraph of the subsection,
and an erroneous reference to "production of alfalfa" (rather than dryland pasture) in Item 3
of the 2 °a paragraph of the subsection. Further, the plan would entail possible fertilization at
intervals during the liability period. Please provide documentation that the proposed
fertilization plan would be consistent with normal husbandry practice for dryland pasture in
the Nucla area, pursuant to Rule 4.15.7(5)(e). Note that if such documentation is not
provided, the liability period would begin after the final year of fertilization.
45. The Division requested delineation of proposed gated irrigation pipe locations for the Morgan
property on Map 2.05.4 -5, and the modifications were made. Item Resolved
Irrigation of Benson/Lloyd /WFC parcels
a. Previously resolved.
b. Previously resolved.
c. Areas of relatively steep slope on in the western portion of the WFC parcel that were not
irrigated prior to mining were excluded from the area of potential future irrigation on Map
2.05.4 -5, in response to Division request. Item Resolved
45A. New Map 2.05.4 -8 has been revised to illustrate postmining contours and the location of
irrigation structures, as requested. Item Resolved
46.47. Previously resolved.
47A. See 44.d.iii, above. Item Resolved
48. Previously resolved.
49. Interim revegetation monitoring plans.
a. The Division requested a number of clarifications to the interim monitoring plan for irrigated
cropland. The plan was revised but it still lacks clarity. The Division recommends the
following replacement language, beginning with the final sentence of the first paragraph of
Subsection 5.6.
For the interim monitoring in Years 5 and 8, a qualified vegetation or agronomy professional
will make an estimate based on visual assessment and /or clipped plot sampling conducted
just prior to I" cut harvest, and report, at a minimum, the estimated percent composition by
weight of alfalfa and the estimated percent composition by weight of permit listed noxious
weeds, for the alfalfa field or fields that would be included within a single block far future
bond release. The report to be prepared based on the evaluation will include a statement of
professional opinion as to whether the subject fields) would meet the bond release criteria of
at least 85% relative production of alfalfa and no more than 1% relative production of
permit listed noxious weeds.