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operator must demonstrate that the management of the reference area is under the <br />permit's control and, will remain under the permittee's control throughout the <br />performance bond requirements of 3.02.3. <br />The Division questions the applicability of the Dryland Reference area located at the <br />Hopkins Field Airport as representative of the pre- mining dryland pasture land use. The <br />soil of the proposed dryland pasture reference area is primarily Barx fine sandy loam 1 -3% <br />slope. The Montrose County soil survey does not provide expected productivity values for <br />dryland pasture on this soil mapping unit. The proposed dryland pasture reference at the <br />Hopkins Field has a considerable shrub component. The post- mining land use for areas on <br />the proposed permit area is dryland pasture. Shrubs should make up a minor component <br />of the dryland pasture "community ". Soils mapped in the proposed mining area do not <br />include Barx soils. The Division contends that WF -C needs to locate a better representative <br />Dryland pasture reference area that can remain under the operator's control. <br />The Division accessed the Soil Resource data through the NRCS Website. The Division was <br />indeed looking at the correct soil survey. This portion of Montrose county soils <br />information is indeed titled "San Miguel Area, Colorado, Parts of Delores, Montrose, and <br />San Miguel Counties ". Interestingly, WF -C was able to find production values in the printed <br />copy of this soil survey that were not readily locatable on the NRCS website. The <br />production data reported by WF -C for the Ecological Sites provides important potential soil <br />productivity information. The Division concurs that Barx soils do exist as minor inclusions <br />to the NRCS mapping units. If no other comparable locations are available for use as a <br />vegetative reference area, the Division will accept the Hopkins Field site. <br />