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C- 1981 -008 MR -118 Preliminary Adequacy Review 23 August 2011 Page 2 of 3 2. Page 38 discusses the Grazing Plan for the Reclaimed Irrigated Pasture during the liability period. a) According to the cover letter submitted with the application, the fourth paragraph on page 38 has been modified to allow either haying or grazing on the reference area. Upon review of the submitted page, it appears that the last sentence of the fourth paragraph has been deleted, but the Division does not find that the paragraph has been modified to include haying as an option. Rather, mention of harvesting on the reclaimed area has been removed. Please review page 38, and revise as appropriate. b) Subsection 4.6.2 is titled "Grazing Plan ". The text discusses both haying and grazing of the Reclaimed Irrigated Pastureland. Please revise the title to reflect the dual nature of the information provided. Additional Discussion The Division's initial approach to the MR -81 application was to simply review the proposed changes for adequacy. During the review process, we became aware of certain contradictory statements made within these sections of the permit, related to both reclaimed Irrigated Pasture and the IP reference area. These observations are summarized below. Subsection 4.5.2 of the permit, as approved with PR -06 in December 2010, is entitled, "Irrigated Pastureland Reference Area Characterization and Management." The majority of text in this subsection has been retained from the version approved with TR -58, although the order of the paragraphs has been revised. The third paragraph on page 29 was new with PR -06, and discusses estimates of mean cover for the 1999 vegetation study. This study, conducted for PR- 05, does not appear to have been incorporated into the New Horizon Mine permit. The section also references the 1987 study conducted by Peabody (for PR -02). The Division believes that the 1987 and 1999 baseline vegetation studies, in toto, should be incorporated in an attachment to Section 2.04. 10 of the New Horizon Mine permit application package. The Reference Area Management portion of Subsection 4.5.2, page 30 was revised with PR -06. As approved in TR -58, the third paragraph of this subsection described the expected application rates of water: Reference area - 10 shares of water to irrigate the reference area of 6.81 acres. It is applied through a connector ditch from the CCC ditch. The reclaimed area will receive approximately I share per acre if a side roll is used. If flood irrigation is used, the same application rate as the reference area is used, which is 1.64 shares per acre. This paragraph was revised for PR -06 to state simply that, Water will be applied to the reference area based on the ration used for the irrigation of Reclaimed Irrigated Pastureland on the Lloyd property. The Lloyd property has not yet been reclaimed, and it is not representative of the reclaimed lands located east of 2700 Road. The Irrigated Pasture Reference Area management section of the