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2010-09-22_REVISION - C1981008
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2010-09-22_REVISION - C1981008
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Last modified
8/24/2016 4:23:20 PM
Creation date
9/22/2010 5:00:56 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
9/22/2010
Doc Name
Response to Adequacy No. 5
From
Greg Lewicki & Associates
To
DRMS
Type & Sequence
PR6
Email Name
MLT
SB1
Media Type
D
Archive
No
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Text has been added to subsection 6.5.1 confirming that interseeding will take place <br />during the first four years of any ten year liability period. <br />The Division requested certain clarifications to the Dryland Pasture fertilization <br />management plan presented in Subsection 6.5.2. The plan was modified to an extent, but <br />we note that there is an erroneous reference to irrigated cropland in the first paragraph of <br />the subsection, and an erroneous reference to "production of alfalfa" (rather than dryland <br />pasture) in Item 3 of the 2 nd paragraph of the subsection. Further, the plan would entail <br />possible fertilization at intervals during the liability period. Please provide <br />documentation that the proposed fertilization plan would be consistent with normal <br />husbandry practice for dryland pasture in the Nucla area, pursuant to Rule 4.15.7(5)(e). <br />Note that if such documentation is not provided, the liability period would begin after the <br />final year of fertilization. <br />Jim Boyd of the local NRCS office approved the dryland pasture fertilization plan <br />in his June 30, 2010 letter. This subsection has not been changed since. <br />45. The Division requested delineation of proposed gated irrigation pipe locations for the Morgan <br />property on Map 2.05.4 -5, and the modifications were made. Resolved. <br />Irrigation of Benson/Lloyd/WFC parcels <br />a. Resolved. <br />b. Resolved. <br />c. Areas of relatively steep slope on in the western portion of the WFC parcel that were not <br />irrigated prior to mining were excluded from the area of potential future irrigation on Map <br />2.05.4 -5, in response to Division request. Resolved. <br />45A. New Map 2.05.4 -8 has been revised to illustrate postmining contours and the location of <br />irrigation structures, as requested. Resolved. <br />46.47. Resolved. <br />47A. See 44.d.iii, above. Resolved. <br />48. Resolved. <br />49. Interim revegetation monitoring plans. <br />xii. The Division requested a number of clarifications to the interim monitoring plan for <br />irrigated cropland. The plan was revised but it still lacks clarity. The Division <br />recommends the following replacement language, beginning with the final sentence of <br />the first paragraph of Subsection 5.6. <br />For the interim monitoring in Years 5 and 8, a qualified vegetation or agronomy <br />professional will make an estimate based on visual assessment and/or clipped plot <br />sampling conducted just prior to !" cut harvest, and report, at a minimum, the estimated <br />percent composition by weight ofalfalfa and the estimated percent composition by weight <br />ofpermit listed noxious weeds, for the a(faljafreld orfields that would be included within <br />a single block for bond release. The report to be prepared based on the evaluation <br />will include a statement ofprofessional opinion as to whether the subject fields) would <br />meet the bond release criteria of least 85% relative production ofalfalfa and no more <br />than 1% relative production of permit listed noxious weeds. <br />
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