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be applauded, since these data confirm exactly what WFC has contended over the years, <br />that this is a good site, with a low shrub cover, indicative of a high ecological condition. <br />Examination of the data collected in 2009 document that when Brome Snakeweed, a <br />native subshrub is subtracted from the shrub composition, then shrubs, consisting of <br />Fourwing Saltbush and Big Sagebrush, account for only 11.87 percent of the composition <br />of this site. WFC submits that this value is very much in line with the potential shrub <br />composition values which would be expected from a reclaimed dryland pasture site. <br />The DRMS comments that "soils mapped in the proposed mining area do not include <br />Barx soils. "It is incorrect and contrary to the information found in the narrative of <br />Section 2.04.9 - Soils Resource Information as well as the NRCS Soils Survey. <br />Examination of this information clearly documents that the Barx soils are found as <br />inclusions in four of the seven NRCS soils mapping units shown on Map 2.04.9-1- NRCS <br />Soils Map. The narrative clearly documents that Barx soils, the only soil type associated <br />with the Dryland Pasture Reference Area site, is the dominant inclusion on soils mapping <br />units 77, 78, 81 and 82, which account for a total of 214.50 acres or 91.13 percent of the <br />soils found on this site and virtually all of the lands which will be reclaimed as Dryland <br />Pasture. On each of these four soils mapping units, the Barx soil is reported to be an <br />inclusion that accounts for approximately five percent of the soils associated with this <br />soils mapping unit. Thus by calculation, it can be determined that Barx soils occur on <br />approximately 10.73 acres of the proposed NHN mine site. <br />Another fact that is very confusing to WFC is the fact that the current NHI reclaimed <br />tract, which according to Map 2.04.10-1- Permit Area Vegetation Map, is the largest <br />single vegetation type associated with the proposed NHN Mine area, occupying some <br />65.55 acres or 20.30 percent of the site and all of the reclaimed Dryland Pasture <br />associated with the NH2 mine all use a common reference area, which is the Dryland <br />Pasture Reference Area, located at the Nucla airport. WFC finds it very difficult to <br />understand why this reference area is acceptable to the DRMS in connection with the <br />existing NH2 Mine Permit but is somehow unacceptable relative to the proposed NHN <br />mine permit area. The Division's logic is very confusing. WFC believes that the airport <br />dryland pasture site is a good location for a proposed reference area site and that it will be <br />better protected and fulfill its desired objective better than any other site in the area. <br />This issue was discussed with DRMS personnel. It was agreed to keep the proposed <br />dryland pasture reference area at the Hopkins Field <br />2.05.5 - Postmining Land Uses <br />1. The post-mining land use map also shows pre-mining land uses. While having both pre-and <br />post-mining land uses displayed on one map provides a good comparison of the land use <br />changes, the map as submitted is very confusing. Please remove the premining land use data <br />from Map 2.05.4-post mining land use, and resubmit it clearly showing the proposed post- <br />mining land use. <br />Response - The pre-mining data has been removed from Map 2.05.4-1. <br />Response to First Adequacy Review Page 43