2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (22)

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A detailed description and accompanying premining Land Use conditions map is found in Section 2.04.3 and on Map 2.04.3 -1 - Land Use Map. In this discussion of postmining land uses, only the current land use definitions found in Section 1.04 and has further clarified in the OSM regulations at 30 CFR 701.5 are used. The extent of these predisturbance land use categories is shown on Map 2.04.3 -1, Land Use Map. This analysis shows that there were a total of four premining land use categories, further broken down into 13 subcategories corresponding to the current or proposed CDRMS land use categories within the areas corresponding to the proposed NHN Mine Area. Each of these corresponding land uses, their corresponding area and the percentage occupied by this specific land use are presented below. Pastureland is the single largest current land use consisting of 208.25 acres and accounts for approximately 64.64 percent of the proposed NHN permit area. Grazingland is the second largest existing land use and consists of 93.60 acres and accounts for approximately 29.05 percent of the proposed NHN Mine permit area. The Residential land use, which includes roads, accounts for 18.77 acres or 5.83 percent of the proposed NHN permit area. Developed water resources correspond to 1.49 acres or 0.46 percent of the proposed NHN Mine Permit Area. Premining Land Use Summary Land use and baseline vegetation studies (Sections 2.04.3 and 2.04.10) conducted during the fall of 2008 and summer of 2009, as well as results obtained from interviews with the current landowners, other local operators and residents in the area along with discussions with local governmental officials, show that the predominate premine land use can be described as being based on agriculture based largely on the availability of irrigation water and the current level of management. Vegetation types such as the Wetland type are present as a result of irrigation in the area and are used and managed in a fashion that is essentially identical to Irrigated Pasture. Baseline studies also show that Wetland and Irrigated Pasture plant communities are very similar in vegetative composition and often are used interchangeably depending on the operator's needs. After several years of production as Irrigated Pasture and/or following -the abandonment of irrigation, the Irrigated Pasture areas become dried out and become dominated by more invasive dryland species and are slowly invaded by species such as Russian Knapweed (Centaurea repens), Quackgrass (Agropyron repens) Kentucky bluegrass (Poa pratensis), Western Wheatgrass ( Agropyron smithii) and Buckhorn plantain (Plantago lanceolata). The most intensively managed areas found on the proposed NHN Mine Area correspond to the Intensively Managed Irrigated Pasture areas found on the Garvey Property, where they are managed at a much higher level of intensity due to regular application of fertilizer and regular changing of the applied water. All areas are used as Pastureland or Grazingland during other periods in the year, especially as winter feeding areas based on operator needs. With the exception of the Intensively Managed Irrigated Pasture areas, management is typically not at a high level. Other than farmsteads, facilities, and a small abandoned orchard, the large extent of natural vegetation consists of the Sagebrush type which makes up most of the balance of the proposed disturbance area. This type reflects significant disturbance of the original sagebrush type and the intensity of use from associated agricultural activities. These sagebrush areas are not irrigated and are typically located on areas that are upslope of the irrigation ditches, where it is impractical to irrigate. As described in discussion of existing Land Uses found in Section 2.04.3 and the Vegetation description found in Section 2.04.10, the postmining land use will be similar to the premining Section 2.05.5 Page 2 April 2011