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17. Please include a legend on Map 2.05.4-1. And please show final reclamation contours for the <br />facilities area including the topsoil stockpile and the boxcut overburden stockpile on this map. <br />18. The diversity standard Proposed in PAP Sec. 2.04.10 p. 4 is unclear. Please elaborate on the <br />proposed diversity standard stated as "The reclaimed plant community shall be composed of at <br />least the dominant species comprising at least 5% of the relative plant cover." <br />19. On Map 2.04.10-2, titled "Adjacent Vegetation", there is a mapping unit identified as JSB that is <br />not defined in the legend. Please add this mapping unit to the legend and define this mapping <br />unit. <br />20. Rule 2.04.3(1) requires a description of the premining environmental resources within the <br />proposed permit area and adjacent areas that may be affected or impacted by the proposed <br />surface mining activity. Environmental resources within the proposed permit area were <br />adequately described by WF-C, but the Division was unable to find discussion of adjacent areas. <br />(a)Please include a discussion of environmental resources adjacent to the proposed permit <br />boundary. <br />Rule 2.04.3(4) requires a description of the premining land uses within the proposed permit <br />area and adjacent areas that may be affected or impacted by the proposed surface mining <br />activity. Land use within the proposed permit area was adequately described by WF-C, but the <br />Division was unable to find a discussion of adjacent areas. <br />(b) Please include a discussion of pre-mining land use adjacent to the proposed permit <br />boundary. <br />21. Rule 2.04.10(2) requires reference areas to be shown on a map. Neither proposed reference <br />area is located within the proposed permit area. The maps illustrating the proposed reference <br />areas, Map 2.04.10-3 and Map 2.04.10-4, do not show where the reference areas are located with <br />respect to the proposed permit area. Please include a sketch or a drawing showing the location <br />of the proposed reference areas relative to the proposed mine location. <br />22. Reference to NRCS Soil Survey of Montrose County, Colorado shows one soil mapping unit found <br />on the proposed permit area is listed as "prime farmland if irrigated". This soil mapping unit <br />corresponds to the Nyswonger 1-4% slopes. WF-C provided a demonstration to declassify this <br />mapping unit on the proposed permit area from "prime farmland if irrigated". WF-C provided <br />data from soil test pits, chemical analysis from baseline soil sampling, historic land use <br />information, lack of irrigation on this mapping unit, and slopes that exceed the prime farmland <br />definition. The Division also notes that NRCS Montrose County, Colorado Soil Survey continues <br />to show the "Rice Tract" reclaimed lands in S 1/2 SW 1/4 Section 25 T47N, R 16W of the New <br />Mexico P.M. as Nyswonger soils. The reclaimed NH1 land would not have the same soil <br />properties as undisturbed Nyswonger soils. WF-C's soil survey did not identify any soils that <br />qualify as Nyswonger, or any other mapping units that qualify as prime farmland (irrigated or <br />not). <br />Please provide a current letter from the local NRCS representative stating that no prime <br />farmland exists within the proposed permit area. (2.04.12(5)(b)), (Act 34-33-111(1)(c)) <br />4