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Greg Lewicki From: greg@lewicki.biz Sent: Wednesday, November 22, 2006 10:29 AM To: Ross Gubka Subject: Fw: New Horizon TR-54 Revegetation Issues ----- Original Message ----- From: Mathews, Dan To: gregtalewicki.biz Cc: Brown. Sandy ; Boulay. Mike Sent: Tuesday, November 21, 2006 2:37 PM Subject: New Horizon TR-54 Revegetation Issues Greg, I think the draft postmine ve elation/ land use ma you emailed esterda enin with on final soil t es overlaid and the proposed reference area for irrigate ands included is definitely a step forward. If it can be shown that the relative area of "productive" soil types (typically irnga e a vs es ss productive" soil types (typically not irrigated in the general area) within the reference area is generally representative of the "high production" irrigated pastures in the permit area, then it is likely that a case can be made for using the proposed reference area cover and production means directly for "high production" irrigated pastureland success comparison. Further, as we discussed, it may be likely that a case could be made for a downard adjustment of the reference area production mean to use as the success standard for "low production" irrigated pasturelands. Further, although we did not discuss the irrigated cropland standard, it might also be appropriate to employ the same reference area production mean with an upward adjustment, as the success standard for the irrigated hay cropland. Use of an appro riate reference area, even ifv adjusted mean values are used as standards for higher production cropland and lower production "less pruc ioit type" pastureland,. would put us on mucf} ii rmer round-fromma-re utator ers ect_ive than use of standards based on limited 4remme data and recommendations 61 "" 9 9 y p._ p NRCS-and-Fo651 farmers. A major advantage of the reference area as opposed-to a technical standard (as long as" m consistent mans9ement can be a pp L? lied to the refere nce area and reclaimed areas is thane reference area autornaficall4"adiugts far' vea?'to vear dlimaticyva-hations. One question I have regarding the draft map, is that the soil map unit designations don't seem to match up with the map units on the Soils Map in the currently approved version of the PAP. From the current soils map, it appears that the deeper, more productive soil map units are designated 98A, 98D, 98E, 98F, and 98G; while shallower, less productive soil types would include 98B, 98C, 98H, 30C (various sub-units), 1 E, 1 EW, and D70B. In contrast, the low productive soil types on the draft reclamation map are designated as Map Unit 77 and 78; high production map units appear to include 14, 15, etc. These discrepancies would need to be clarified, so that the soil map units used on the postmine reclamation map can be correlated to the map units used on the baseline soils map. Also, there is a 37.84 acre reclaimed irrigated pasture parcel located immediately northeast of the intersection of 2700 Road and BB Road. Based on both soil mapping systems (the one used in the draft reclamation map and the one from the current Soils baseline map), it appears that this parcel is contained almost completely within a "high production" soil map unit. As such, it would appear that the success standard for this parcel should be based on the "high production" irrigated pasture standard rather than the "low production" irrigated pasture standard. The proposal to use 2700 road as the sole "divider" between "high production" and "low production" areas may need to be reconsidered, given that this high production soil parcel is located east of 2700 road. The lower production soil types appear to predominate in the areas east of 2700 Road and south of BB Road. I think Sandy and Mike will be sending out an adequacy letter with my review comments on TR-54 shortly. I think the reference area approach presented in the draft map, with the possibility of adjustments for use in success comparison for low production soil types and irrigated hayland as discussed, may be a route to resolve the concerns expressed in that letter regarding irrigated pastureland and cropland success standards. Final approval of the proposed reference area will likely require submittal of cover and production sample data from the proposed reference area and representative permit area fields (that have not yet been disturbed). So there would need to be some data collection performed this coming summer. Because final resolution of the vegetation issues will take awhile to work out, i think Mike is leaning toward asking you to separate out the unresolved vegetation issues, and submit responses to the forthcoming adequacy letter as