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in the reference area, reverse null testing would employ Satterthwaite <br />corrected two sample Westing. <br />18.OMLR noted that the mid summer timefratne for sampling specified in the application <br />might be overly restrictive, given the growth patterns of the introduced cool season pasture <br />grasses and legumes utilized in the New Horizon Reclamation. The section was properly <br />revised. Igo Resolved. <br />New Review Comments <br />19. The Tab 22 Table of Contents does not correspond to the page numbers of the amended <br />Tab 22 narrative, tables, and appendices. Please ahead the Table of Contents section as <br />appropriate. <br />20. Table 22-5 indicates that the production standard for NH-1 dryland pasture reclamation is <br />to be based on comparison to a technical standard of 500 pounds per acre. For the same <br />basic reason discussed above under Comment 13, use of a technical standard for <br />production is problematic. A dryland pasture reference area has been established for <br />demonstration of successful cover establishment, and we believe it would be appropriate to <br />designate the same reference area to be used as the method for demonstration of dryland <br />pasture production success comparison. Please amend Table 22-5 to specify use of the <br />drylaud pasture reference area hr NR-1 production success demonstration. <br />21. There currently are no species diversity success criteria applicable to the pastureland or <br />cropland types within the NH I or NH-2 mine areas. Diversity requirements had been <br />waived in the past, due to the focus on establishment of a relatively small number of <br />improved pasture grasses and legumes. OMLR believes it is true that traditional diversity <br />criteria applied to rangeland and wildlife habitat reclamation areas are not appropriate for <br />New Horizon agricultural lands. However, as discussed at the mine site meeting on May <br />2, 2006, involving NRCS, OMLR, and WFC representatives, criteria to ensure that <br />reclaimed area vegetation is of acceptable quality (i.e. primarily composed of desirable <br />species) is warranted. An example of the type of criteria that might be appropriate would <br />be: "At least 75% of the relative cover or relative production will be comprised of seeded <br />species or species of comparable quality as livestock forage, and no more than 3% relative <br />cover or relative production will be comprised of county listed noxious species". Because <br />cropland areas might otherwise be harvested and not sarnpled, sampling of cropland areas <br />to make the relevant demonstration would be necessary. For the purposes of the "quality" <br />demonstration, species composition perceRtages based on a statistically adequate cover or <br />production sample, or minimum of 30 observations, would be acceptable. Finally, because <br />Jim Boyd of NRCS brought up this concern at the May meeting, please contact him in <br />regard to development of appropriate "quality" standard or standards. <br />Please amend the reveptation success demonstration- success sections of the <br />application to intrude species composition qualily criteria for NH-1 and NH-2 <br />dryland pasture, irrigated pasture, and irrigates cropland vegetation types, <br />• WFC Exhibit/ <br />Page 9 of 11