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• <br />• <br />dominated by "dense woody cover and a weak herbaceous understory or poor condition <br />rangeland dominated by weedy annuals or other undesirable species a `modified' reference area <br />... might be appropriate." Upon subtracting the annual and weedy species component from the <br />Dryland Pasture predisturbance areas the "allowable plant cover" value equals 17.70 percent <br />(Appendix Table 2.04.10 -9, Irrigated Pasture - Plant Cover). Upon comparing the "total <br />allowable cover" on the proposed Dryland Pasture predisturbance areas with the "total plant <br />cover" value on the existing Dryland Pasture Reference Area, which contains significantly fewer <br />annuals and no noxious weeds, it can be determined that the calculated t value for "total <br />allowable plant cover" was determined to be equal 0.1583, which means that these cover values <br />are statistically equal. This comparison and accompanying discussion documents that it is <br />inappropriate to compare these areas with respect to total plant cover since it involves comparing <br />a very poor ecological condition site to one in higher condition. Based upon this comparison, <br />WFC feels justified in proposing to use the existing Dryland Pasture Reference Area as a success <br />standard for the Dryland Pasture predisturbance area since it is already the approved revegetation <br />success standard of the Dryland Pasture predisturbance area at the NH2 Mine. <br />Intensively Managed Irrigated Pasture. Disturbance to all lands corresponding to the <br />Intensively Managed Irrigated Pasture vegetation type (IMIP) are shown on Map 2.04.10 -1, <br />Permit Area Vegetation Map. This vegetation type is found only on lands owned and managed <br />by the Garvey & Co. and differs from regular irrigated pasture for the reasons previous <br />described. The owners of this land desire that these areas be reclaimed to a similar condition <br />following mining and reclamation. <br />Extensive investigations into numerous other similar Intensively Managed Irrigated Pasture sites <br />in the existing NH2 Mine area, reveals several potential similar sites, but upon consultation with <br />the owners, it was determined that none were willing to cooperate with WFC by allowing them <br />to dictate on how they had to manage their lands, when they could cut hay and or place cattle on <br />them. After this extensive investigation and following discussions with Ms. Sandy Brown of the <br />DRMS, wherein we inquired about the feasibility of using a "Historic Record" method of <br />formulating a final revegetation success standard for these sites, IME was informed that WFC <br />could use the "Historic Record" approach provided that at least three years of data were collected <br />on these areas prior to any mining disturbance. Accordingly, WFC will monitor all of the <br />Intensively Managed Irrigated Pasture sites for three years prior to mining. As allowed in the <br />Division's Guidelines for Compliance with Land Use and Vegetation Requirements for Coal <br />Mining, the plant cover and forage production data will be sampled for three years and these <br />corresponding cover and production values will be averaged into an overall mean value which <br />will then be used as the revegetation success standard for cover and production for this <br />vegetation type. The result for the second monitoring effort conducted in June 2010 is included <br />in Appendix 2.04.10A. The result for the third monitoring effort will be supplied to the Division <br />after the completion of the survey likely to take place in June 2011 and will be included in <br />Appendix 2.04.10B. <br />Section 2.04.10 Page 33 April 2011 <br />