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proposal to re-establish the reclaimed lands to an "improved/irrigable" post-mining use may be <br />a valid approach. <br />12. Seed mix No. 8 shown in PAP Section 2.05.4(2)(e) page 12 is different from the seed mix shown <br />on page 24. Seed mix No. 8 shown on page 24 is acceptable to the Division. Please correct Seed <br />Mix No. 8 on page 12 to be in agreement with the seed Mix No. 8 shown on page 24. <br />13. On permit application section 2.05.4(2)(e) page 26, there is a Discussion regarding sampling <br />methods to determine reclamation success in the dryland pasture. WF-C makes the statement <br />that, "Vegetation cover will be measured as either canopy or basal cover of living herbaceous <br />and woody vegetation..." Please commit to one method or the other. <br />14. Please resubmit Table 2.04.10-9: Irrigated Pasture Cover page 49; Part of this table was <br />obstructed during PAP compilation. Please resubmit Appendix Table 2.04.10-9 so all of the data <br />is legible. G <br />15. Dryland Pasture Reference area. WF-C proposes to use a dryland pasture reference area located <br />approximately 4 miles away from the mine site at the Hopkins Field Airport in Montrose County. <br />This Dryland Pasture reference area has previously been approved for reclamation success <br />comparison for the New Horizon No. 2 permit. In accordance with 4.15.7(3)(b)(ii), please <br />provide verification that WF-C retains the right-of-entry for surface activities on the Dryland <br />Pasture reference area. Documentation similar to that found in New Horizon Mine permit, <br />C1981008, Attachment 2.05.4(2) (e)-4, would be suitable to document WF-C's right of entry. <br />(Rule 2.03.6(1)). <br />16. Rule 4.15.7(3)(b)(iii) requires that reference areas selected for reclamation success comparison <br />should approximate the vegetation characteristics which reflect reclamation plan objectives. <br />The permittee must demonstrate that the reference area selected reflects proper land <br />management and is representative of the ecological site conditions for the reclaimed area as <br />determined by pre-mining inventories and the reclamation plan. The operator must <br />demonstrate that the management of the reference area is under the permit's control and, will <br />remain under the permittee's control throughout the performance bond requirements of 3.02.3. <br />The Division questions the applicability of the Dryland Reference area located at the Hopkins <br />Field Airport as representative of the pre-mining dryland pasture land use. The soil of the <br />proposed dryland pasture is primarily Barx fine sandy loaml-3% slope. The Montrose County <br />soil survey does not provide expected productivity values for dryland pasture on this soil <br />mapping unit. The proposed dryland pasture reference at the Hopkins Field has a considerable <br />shrub component. The post-mining land use for areas on the proposed permit area is dryland <br />pasture. Shrubs should make up a minor component of the dryland pasture "community". Soils <br />mapped in the proposed mining area do not include Barx soils. The Division contends that WF-C <br />needs to locate a better representative Dryland pasture reference area that can remain under <br />the operator's control. ,