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2011-03-17_REVISION - C1981008 (2)
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2011-03-17_REVISION - C1981008 (2)
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Last modified
8/24/2016 4:31:49 PM
Creation date
3/17/2011 1:05:37 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
3/17/2011
Doc Name
Response to 2nd Adequacy Review
From
Greg Lewicki and Associates, PLLC
To
DRMS
Type & Sequence
SL12
Email Name
MLT
SB1
Media Type
D
Archive
No
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Land management involves more than just seeding and doing nothing more. The Division <br />needs additional information regarding how was the reclaimed irrigated pasture <br />managed? Management methods should make it clear why this parcel is considered <br />Irrigated pasture and not a different post-mining land use as defined by Rule 1.04(71). <br />Narrative regarding irrigation and grazing practices on Irrigated Pasture (Phase 2) can be <br />found on pages 14 and 15 of the revised release application. <br />Please have WFC explain why the values of "Total Desirable Cover" for Irrigated Pasture <br />reclaimed Area sampled in 2007 different on page 32 of the SL-12 20Augl0 revised page <br />(submitted August 30, 2010) than Table 1, on page 10, in Bio-Logic vegetation sampling <br />report? Page 32 of Application states this value, "total desirable cover" as 88.3%, yet <br />Table in the Bio-Logic report documents this value as 87.1 % cover. Please explain the <br />discrepancy. <br />Annual grasses were erroneously included in the calculation of total desirable cover within <br />the release application. The values shown in the Bio-Logic sampling report are the correct <br />values, and Table I has been corrected to match. <br />9. WFC provided a description of reclamation history but chose not to include any <br />discussion of the management history. Was the Irrigated Pasture grazed? Was there any <br />irrigation conducted? If so, what method of irrigation was employed? How often was it <br />irrigated? how much water was applied? Was the pasture cut for hay? How was the <br />Dryland pasture managed? Was the pasture interseeded during liability period? Was there <br />any fertilization on either the reclaimed areas or the reference areas? WFC did include a <br />very brief discussion regarding noxious weed management. Please provide the Division <br />with a narrative of the management of the two reclamation blocks; irrigated pasture and <br />Dryland pasture. Were the reclaimed areas managed in accordance with the approved <br />permit and WFC needs to describe how they were managed. Please, also, include <br />information, as approved in the permit, regarding the reclamation standards. Section <br />2.05.4(2)(e) of the permit defines the reclamation success requirements. Please include <br />this detail in the application. <br />Narrative can be found on page 33 of the revised bond release application addressing <br />management history of the reclaimed Irrigated Pasture area. Irrigation and grazing activities <br />are included in this discussion.
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