2012-06-20_PERMIT FILE - C2010089A (13)

Home Browse Search

Big Sagebrush vegetation type yielded 123.3 pounds, Irrigated Pasture produced 3,285.3 pounds, Dryland Pasture produced 348.6 pounds, Intensively Managed Irrigated Pasture produced 6,387 pounds and the Wetland vegetation type yielded 5,037.4 pounds of air -dry forage per acre. Application of the forage palatability rankings for the five most dominant plants, as found on the USDA Plants website, wherein plants are ranked as low, medium or high with respect to grazing animal palatability yields the following comparison. In terms ranking of the plant communities possessing the forage rankings of "high," expressed in pounds of forage considered to have a "high" ranking, the plant communities on the NHN Mine would be ranked as follows. Intensively Managed Irrigated Pasture 6,387 pounds, Irrigated Pasture 3,285.3 pounds, Wetlands 947.5 pounds, NH1 Reclamation 845 pounds, Dryland Pasture 348.6 pounds and Big Sagebrush 0 pounds of air -dry forage having a forage palatability ranking of "high." Discussions with Mr. Preston Carver and Mr. Roy Case, documented in Section 2.04.3 - Site Description and Land Use Information, reveal that most ranches in this area consider the wetland type to have a relatively low value for grazing due to the wetness of the areas and the fact that livestock often are mired in the mud and become crippled or die. This comparison, documents in WFC's opinion that the Wetland vegetation type or Grazingland - Subirrigated land use areas do not have any particular agricultural significance to this site and since these areas can be viewed as a determent to the effective utilization and management of these lands. The DRMS regulations are particularly silent in giving any specifics regarding the topographic characteristics of "upland areas" which would not be considered to be AVF's other than saying that such areas are "located outside of the floodplain and terrace complex" in "higher" or "highland areas." However, there is sufficient data available to document this issue. Firstly, with respect to the NRCS Soil Survey, Chiles and Meehan Draws are mapped as corresponding to soils mapping unit 10, Aquolls, 0 to 3 percent slopes while the lands associated with the proposed Tuttle Draw equipment corridor are mapped as Nyswonger Silty Clay Loam, 1 to 4 percent slopes. Application of these slope criteria, would suggest that in the Nucla area, soils derived of alluvium would typically have slopes less than 4 percent. As documented in Section 2.04.9 - Soils Information and in this section, none of the alluvium derived soils mapped by the NRCS correspond to this criterion. Thus, it can be concluded that based upon this criterion, the NRCS soils mapped as corresponding to soils mapping unit 10, in actually pertain to the 5 percent and 10 percent inclusions of other soils included in these two soils mapping units. Since in all of these areas, the measured slopes exceed the slopes reported by the NRCS, it can be concluded that the NRCS soils mapping units on this site pertain to inclusions and not the actual soil mapping units. In the DRMS adequacy review meeting held in Grand Junction on February 1, 2011, they requested that Appendix 6 -1 from the NH1 Permit Application be copied and included in the NUN Mine Permit Application. Extensive searches performed by WFC at both their Nucla Mine Office and in the files of their Denver office, failed to locate this information. In a subsequent adequacy review meeting held in the DRMS office in Denver on February 11, 2011, this situation was explained and the DRMS informed WFC, that they did not need to include this information. Section 2.06.8 Page 7 April 2011