2012-01-13_APPLICATION CORRESPONDENCE - C2010089 (2)

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C -2010 -089 New Horizon North Mine PARNos. I- IA -IB, 2- 2A -2B, 3 Page 48 of 60 reference area has previously been approved for reclamation success comparison for the New Horizon Mine permit. In accordance with 4.15.7(3)(b)(ii), please provide verification that WFC retains the right -of -entry for surface activities on the Dryland Pasture reference area. Documentation similar to that found in New Horizon Mine permit, C -1981- 008, Attachment 2.05.4(2)(e) -4, would be suitable to document WFC's right of entry. (Rule 2:03.6(1)), Item re.volred in Atay -2011 resl)t nse. 4. Rule 4.15.7(3)(b)(iii) requires that reference areas selected for reclamation success comparison should approximate the vegetation characteristics which reflect reclamation plan objectives. The permittee must demonstrate that the reference area selected reflects proper land management and is representative of the ecological site conditions for the reclaimed area as determined by pre - mining inventories and the reclamation plan. The operator must demonstrate that the management of the reference area is under the permit's control and, will remain under the permittee's control throughout the performance bond requirements of 3.02.3. The Division questions the applicability of the Dryland Reference area located at the Hopkins Field Airport as representative of the pre - mining dryland pasture land use. The soil of the proposed dryland pasture reference area is primarily Barx fine sandy loam 1-3% slope. The Montrose County soil survey does not provide expected productivity values for dryland pasture on this soil mapping unit. The proposed dryland pasture reference at the Hopkins Field has a considerable shrub component. The post-mining land use for areas on the proposed permit area is dryland pasture. Shrubs should make up a minor component of the dryland pasture "community ". Soils mapped in the proposed mining area do not include Barx soils. The Division recommends that WFC locate a representative Dryland pasture reference area that will remain under the operator's control. It is desirable and highly beneficial to use a reference area that can be incorporated into the permit area. The Division accessed the Soil Resource data through the MRCS Website. The Division was indeed looking at the correct soil survey. This portion of Montrose county soils information is titled "San Miguel Area, Colorado, Parts of Delores, Montrose, and San Miguel Counties ". Interestingly, WFC was able to find production values in the printed copy of this soil survey that were not readily locatable on the NRCS website. The production data reported by WFC for the Ecological Sites provides important potential soil productivity information. The Division concurs that Barx soils do exist as minor inclusions to the NRCS mapping units. If no other comparable locations are available for use as avegetative reference area, the Division will accept the Hopkins Field site. Itent resoh,ed in Alky-2011 rrsi-7on 5. A distinction was made in Section 2.04. 10, page 31 -33, between Irrigated Pasture (IP) and Intensively Managed Irrigated Pasture (IMIP). It is explained that a reference area approach will be used for the IP areas and a "Historic Record" method will be used for IMIP areas. In Section 2.05.4(2)(e) the distinction between the two different land management practices is not as clear. Revegetation methods, Success Criteria and Success Demonstrations are explained for the IP areas, but are not explained for the IMIP areas. Please include in the PAP an explanation of the Revegetation methods, Seeding Procedures, Bond Liability Period Management, Soil Analysis, Success Criteria, Success Demonstrations and how the "Historical Record" will be utilized for the IMIP areas.