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2011-06-10_REVISION - C1981008
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2011-06-10_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 4:34:24 PM
Creation date
6/13/2011 8:38:51 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
6/10/2011
Doc Name
Response to DRMS Letter Dated 5/31/2011(Hand delivered)
From
Greg Lewicki & Associates, PLLC
To
DRMS
Type & Sequence
SL12
Email Name
SB1
MLT
Media Type
D
Archive
No
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that have had grazing limited in this way. Therefore this statement will be removed from the SL-12 <br />application. <br />Calculated Comparison of Grazing Rates <br />As part of working with the local farmers, and being a good neighbor, WFC allows the ranchers to <br />manage their herds with little interference. The only requirement from WFC is that, between haying and <br />grazing, the vegetation reaches the same stubble on all areas (reclaimed and reference) prior to the start <br />of a growing season. Therefore, calculations of the grazing rates are based on some assumptions. These <br />assumptions include: the number of livestock on a field does not vary during a season, there is no travel <br />time between different fields, management of the herds is at 100% efficiency, etc. <br />Cattle grazing on the reclaimed irrigated pasture and IP reference area break down approximately as <br />follows (these values include a correction of the cattle distribution based on further discussions with <br />ranchers): <br />Livestock between BB Road and 5th Road = 20 <br />Area grazed = -190 acres <br />Time frame = Mid-November to Mid-March = 98.5 days <br />(February & March grazing time of 50% is assumed, since cattle are partially fed with hay by farmers at this point, reducing the impact of <br />their grazing) <br />Grazing Rate = 0.0960 acres per head of livestock per day grazing <br />Livestock south of 5th Road = 150 <br />Area grazed = -130 acres <br />Time frame = One month = 30 days <br />(grazing on south of 5th Road is not augmented by hay) <br />Grazing Rate = 0.0002 acres per head of livestock per day grazing <br />Total Reclaimed Areas Grazing Rate = 0.0962 -- 0.10 acres per head per day <br />Livestock on the reference area irrigated pasture= 10 <br />IP reference area = 6.8 acres <br />Time frame = End of June to End of September = 92 days <br />(to simulate the multiple hay cuttings on the reclaimed area) <br />Reference Area Grazing Rate = 0.007 acres per head of cattle per day grazing <br />It is important to note that since the grazing on the IP reference area takes place during the grazing <br />season, the plants provide additional sustenance to the livestock without a net loss in vegetation. This is <br />not the case with winter grazing on the reclaimed area, since the plants are dormant. Also, both of the <br />areas (reclaimed and reference) are grazed to the same final height (stubble), so each starts the following <br />growing season from the same point. <br />Definition of "stubble" <br />Stubble, for the purposes of the New Horizon #2 Mine, is an average vegetation height of one to two <br />inches following haying and grazing. Some vegetation is not grazed down to this height, depending on <br />the grazing animals preference, but it is the target and what most vegetation achieves. <br />
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