2012-12-06_REVISION - C1981008 (4)

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Upon a careful comparison of Exhibit 2007 -4 2007 Seeding Map and Exhibit 2007 -14 2007 Reseeding & Rodent Control Management Areas Map found in the 2207 AAR, wherein these maps are superimposed on each other in AutoCAD, it can be calculated that of the 6.6 acres of disturbance corresponded to the 1998, 1999, 2001, 2002 and 2003 reclamation years. In 2007 there was 8,667 SF or 0.20 acres of disturbance to the 1998 reseeded area, 20,011 SF or 0.46 acres of disturbance to the 1999 reseeded area, 117,915 SF or 2.71 acres of disturbance to the 2000 reseeded area, 101,957 SF or 2.34 acres of disturbance to the 2001 reseeded area, 31,272 SF or 0.72 acres of disturbance to the 2002 reseeded area, and 10,494 SF or 0.24 acres of disturbance to the 2003 reseeded area. According to the yearly reseeding acreages found in Exhibit 2007 -4 2007 Seeding Map, wherein it is reported that in 1998 a total of 31.41 acres reseeded, in 1999 21.34 aces were reseeded, in 2000 19.24 acres were reseeded, in 2001 40.19 acres were reseeded, in 2002 11.99 acres were reseeded, and in 2003 5.09 acres were reseeded. This means that application of the five percent threshold for these respective areas, found in Rule 4.15.7(5)(a) would equal, 1.57, 1.07, 0.96, 2.01, 0.60 and 0.25 acres for the years 1998 through 2003, respectively. As summarized in the previous paragraph, in 2007 there was disturbance corresponding to 0.20, 0.46, 2.71, 2.34, 0.72, and 0.24 acres of disturbance to the 1998 through 2003 reseeded areas, respectively. This means that the disturbance to the 1998, 1999, 2002 and 2003 reclaimed areas is well within the allowable limits, with only questions being raised about the exclusions of 2.71 acres (2.10 acres allowable) for the 2000 reclamation and 2.34 acres (2.01 acres) allowable for the 2001 reclamation disturbances. However, upon a careful comparison of Exhibit 2007 -4 2007 Seeding Map and Exhibit 2007 -14 2007 Reseeding & Rodent Control Management Areas Map found in the 2007 AAR, it can be readily observed as have been recalculated by WFC, that the vast majority of these impacts are actually access road impacts, which did not result in impacts to respread topsoil or the reclaimed vegetation and did not result in these areas being "Retopsoiled & Reseeded. " Therefore the revised calculations of WFC wherein they have determined that two thirds of the original reported impacts did not involve "Retopsoiled & Reseeded" areas, these values would be reduced by approximately two thirds meaning that the revised figures would be approximately 1.82 acres (2.71 acres X 0.67) and 1.57 acres (2.34 acres X 0.67), well below the five percent threshold. WFC believes that these calculations document that this 2007 disturbance was well within the five percent threshold allowed by Rule 4.15.7(5)(a) and that these areas are eligible for final bond release at this time. The Irrigated Pasture Reference Area was formally approved by the CDRMS in the spring of 2007 and this was the first year in which vegetation monitoring data was collected on this area. There was no rill or gully repair work was performed on this site. Weed control was identical to that for the Irrigated Pasture Bond Release Areas. Fertilizer, was applied to the Irrigated Pasture Reference Area in the spring of 2007 and SL -14 03DEC12.wpd 21