2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)

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The DRMS appears to have consulted the wrong soil survey in making many of their conclusions. This site is not located in the "Montrose County soil survey" as stated but is instead, as documented in Section 2. 04.9 page 2, located in areas mapped in the "Soil Survey of San Miguel County Area, Colorado - Parts of Dolores, Montrose and San Miguel Counties." The DRMS appears to be mistaken in stating that the ARCS soils survey "does not provide expected productivity values for dryland pasture on this soil mapping unit." They are correct in noting that Table 5A, Land Capability and Yields Per Acre of Crops and Pasture "found on page 206 of the ARCS soil survey, and which is reproduced as Table 2.04.3-2, ARCS Land Capability & Yields Per Acre by Ecological Sites does not contain any production values for "nonirrigated areas" but this information is found in Table 7, Ecological Sites and Characteristic Vegetation, found on page 218 of the soil survey. Therein, it states that this soil corresponds to the Semidesert Sandy Loam Ecological Site, and that in its natural condition this soil produces 600, 850 and 1,000 pounds of vegetation per acre, respectively. In its undisturbed or ecological climax condition, this site is dominated by Wyoming Big Sagebrush, Galleta, Needle and Thread, Indian Ricegrass and Western Wheatgrass, which contribute approximately 15 percent each of the composition of the vegetation. These are forage production values under "nonirrigated" or "dryland conditions' and it is logical to assume that similar forage production values can be expected under similar conditions. The fact is that the forage production values produced on the existing Dryland Pasture Reference Area, as compared to the ARCS data found in Table 2.04.3-2, ARCS Land Capability & Yields Per Acre by Ecological Sites, are considerably higher than the 100, 300, 500 pounds per acre currently being produced by the Pinion and Ustic Torriorthents soils or the 400, 600 and 800 pounds of forage being produced by the Progresso soils found in the NHN mine area. Examination of the vegetation sampling data contained in Section 2 04.10 - Vegetation Information, document that the average plant cover on this site, based upon the 2009 sampling averaged 24.83 percent, while the herbaceous forage production averaged 299.4 pounds of air-dry-forage per acre. This compares with the values of 26.60 percent cover and 123.3 pounds of air-dry forage per acre for the Big Sagebrush vegetation type and 39.20 percent and 348.6 pounds of air-dry forage per acre for the Dryland Pasture vegetation type. WFC submits that these data document the similarity of these areas. If anything can be said about the forage production of the existing NH2 Dryland Pasture Reference Area, it would be that this site is on the high side as far as a proposed reference area site is concerned and the DRMS should be pleased to see that WFC is proposing this high of a reference area standard. The concerns raised by the DRMS regarding the relative high shrub component of the existing Dryland Pasture Reference Area are difficult to understand and are thus somewhat difficult to address. According to the data in the NRCS soils survey found in Table 7, Ecological Sites and Characteristic Vegetation, Big Sagebrush is the dominant plant species found on this site and under ecological climax conditions should account for approximately 15 percent of the composition of the vegetation produced on this site. The fact that it now accounts for only 4.75 percent of the total relative cover on this site should Response to First Adequacy Review Page 42