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• <br />• <br />to their predisturbance conditions. This means that only the Irrigated Pasture lands on the <br />Garvey Property will be reclaimed as irrigated pasture. <br />The reference area approach will be used to document final revegetation success of lands <br />reclaimed as Irrigated Pasture vegetation areas. Upon comparing the required plant parameters <br />of plant cover and production between the proposed Irrigated Pasture predisturbance areas and <br />the Irrigated Pasture reference area, and using the "t - test" pre- mining comparison found on page <br />16 of the Division's Guidelines for Compliance with Land Use and Vegetation Requirements <br />for Coal Mining, the calculated h value for plant cover was determined to equal 0.6231 and the <br />calculated h value for forage production was determined to equal 0.0892. The corresponding <br />tabular t value for plant cover was determined to be equal to 2.008 and 1.982 for production. <br />Since the calculated h values are less than the corresponding tabular t values, it can be <br />concluded that the Irrigated Pasture predisturbance area is statistically similar to the Irrigated <br />Pasture Reference Areas with respect to the required parameters of plant cover and forage <br />production. <br />Drvland Pasture. Disturbance to all areas corresponding to the Dryland Pasture vegetation type <br />(DP) shown on Map 2.04.10 -1, Permit Area Vegetation Map as corresponding to the DP areas, <br />will be reclaimed according to the currently approved land use of dryland pasture. The currently <br />approved Dryland Pasture Reference Area is located on the west side of the Hopkins Field <br />Airport. No changes are proposed beyond what the DRMS has already approved for this site in <br />the existing NH2 Mine Permit. Since DRMS has already approved the proposed revegetation <br />success standards for this type, no changes are being proposed for this vegetation type. <br />Upon comparing the proposed Dryland Pasture disturbance areas with the existing Dryland <br />Pasture Reference area, it can be determined that the calculated h value for total plant cover <br />equals 4.71 and the calculated t value for forage production equals 0.1918. The corresponding tt <br />values are 2.042 for plant cover and 1.986 for forage production. This comparison documents <br />that the total plant cover between these two sites is statistically different, while forage production <br />is statistically similar. One obvious explanation for these differences is the fact that upon <br />examination of Appendix Table 2.04.10 -9, Irrigated Pasture - Plant Cover, it can be readily seen <br />that the "total plant cover" value is 39.20 percent and the "allowable cover value," which takes <br />into consideration the requirements of Section 4.15.7, which requires that annuals and noxious <br />weeds be excluded from the final revegetation success calculation is only 17.70 percent. <br />Applying the same logic to the pre- mining vegetation comparison, means that if the DRMS <br />requires that annual and noxious weed cover is applied to the pre - mining comparison, they <br />would be requiring that reclaimed lands must be reclaimed to a lower ecological condition than <br />that associated with the approved reference area, which is contrary to the regulations that require <br />that all lands be reclaimed to a higher or more productive condition. <br />The Division's Guidelines for Compliance with Land Use and Vegetation Requirements for <br />Coal Mining acknowledges this contradiction on page 11 where it states that in vegetation types <br />• Section 2.04.10 Page 32 April 2011 <br />