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Stindt from NRCS and the local farmers feel that the Bar soil production figures were <br />very optimistic and the only way to really achieve those tonnages would be to spend <br />large amounts of money in fertilizer and water during the year and then only maybe <br />make the necessary tonnage to pass the hurdle rate. When I say large amounts of <br />money, our preliminary numbers are showing WFC is spending $320 per ton in <br />growing the hay and market value is close to $85 per ton. The last point I would like <br />to make is that the general farm management practices in the Nucla area only call for <br />two cuttings per year from irrigated hay fields. Most farmers in the area do not feel <br />the third cutting is worth their effort and they usually just let their livestock graze what <br />would be the third cutting. Without three cutting, no one in the area would ever <br />achieve the present yearly yield that WFC is presently committed to get. <br />1b. I believe I covered this question in my answer above in "1a."' <br />1 c. No response is necessary. <br />2. Listed below is a portion of my original cover letter dated January 28, 1998, that <br />should answer your question: <br />"Western Fuels -Colorado is requesting the Division's approval to change the revegetation <br />production standards (tons per acre per year) and method of measuring the production for <br />Irrigated Hayland and Irrigated Pasture categories. I have recently reviewed our present <br />approved yearly production tonnage requirement verbiage and feel that the standards are <br />over optimistic and unrealistic for the farm management practices being conducted in <br />the Nucla-Naturita area. The permit verbiage in our present permit was written by the <br />Peabody Engineering Staff that was located in Flagstaff Arizona. We know that they were <br />very optimistic in other categories of this permit as well. Peabody Engineering did however, <br />conduct a detailed study in 1987 dealing on this subject, tons of product per acre, and used <br />five different local farmers. The study was very detailed and the results appears realistic to <br />me. Peabody reported the results (1987 study) in the permit but then proceeded to not use <br />this wonderful data. They instead, decided to set the production standards by using SCS soil <br />types. I fail to see why they made this turn of events....." <br />"The second part of this TR is the method of establishing the production yield. The approved <br />method is for WFC to cut, bale, count and weigh the bales to establish Ibs/ac production from <br />each vegetation type. WFC has made a consciences effort for the last'two growing seasons <br />to do this by using local contract farmers and have come up short handed each time. What <br />we found was: <br />r: \da to\wpdata\revi sions \tr36. doc Pdge 2 <br />