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term successful establishment of pasture stands adapted to dryland conditions. OMLR had <br />suggested consideration of modified practices for dryland pasture establishment irrigation, <br />but WFC apparently has decided to eliminate the practice of irrigation for establishment <br />entirely, for dryland pasture plantings. The referenced text description on page (e)- 11 was <br />properly deleted. However, there is a second brief reference to irrigation for establishment <br />of dryland pasture on amended page (e)-33. Please delete the reference to drybed <br />pasture irrigation for estrablisbarent in the First full parsgrapb on amended page <br />2.O A2)(e)-33. <br />See new comment 24 regarding the need far more detail on practices associated with <br />dryland pasture seedings, if irrigation for establishment will not be used. <br />12.OMLR had questioned whether water availability and water rights were sufficient to <br />ensure that irrigation would continue to be feasible on irrigated pasture and cropland <br />following bond release, due in part to the fact that permit information indicated an increase <br />in irrigated acreage of 77 acres, following reclamation. Revised acreages for various land <br />use categories presented in the amended application indicate that the area of irrigated land <br />(excluding drainage swale:s) is actually reduced by approximately 12 acres on the postmine <br />landscape, compared to premine. WFC indicated their belief was that "sufficient water is <br />available since WFC is able to use the water currently..." Please verity tbat there have <br />bees too water rigbts transfers or otber Fba ages in recent years that would preclude <br />landowners from continuing to irrigate a!l of the irrigated reelsaado n sereage <br />following baud release. <br />13.OMLR had requested relatively minor clarification regarding the established standards <br />applicable to irrigated hay cropland and irrigated pastureland. Subsequently, WFC became <br />concerned based on recent production records for reclaimed fields, that the approved 1.5 <br />ton per acre standard for reclaimed irrigated pastureland might be excessive, for at least a <br />portion of the siu, given the soil types present and other factors. As a result, the operator <br />contacted a number of local farmers and the NRCS Norwood Area Resource <br />Conservationist, and gathered support for a proposed reduction of the standard from 1.5 <br />tons per acre to 1.0 tons per acre for a portion of the irrigated pasture reclamation, <br />specifically the, reclaimed irrigated pasture areas east of 2700 road. <br />This request to lower the standard has had the effect of re-opening the concept of the use of <br />technical standards to scrutiny. Technical standards have beery approved for use at the <br />mine since initial permitting in the 1980'x. Them is a good synopsis of the reasons for use <br />of technical standards for irrigated lands in the permit area on pages 2.04.10-17 and <br />2.04.10-18 of the PAP: <br />it was peabody s opinion and is WFC's opinion that adequate reclamation success <br />standards can be developed without the use of reference areas with the exception of <br />cbyland pasture. Baseline sampling during the 1987 field season reconfirmed the <br />great variation in management objectives of individuals and the highly diverse <br />nature of the soils, geology and ground and swj we water regimes. In many cases <br />the management plans of operators (both within and adjacent to the study area) <br />• WFC Exhibi 2 <br />Page 5 of IV