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Cramer, Johanna <br />From: Mathews, Dan <br />Sent: Monday, November O6, 2006 4:06 PM <br />To: Brown, Sandy; Boulay, Mike <br />Cc: Cramer, Johanna <br />Subject: New Horizon TR-64 Adequacy Review Memo <br />Attachments: 11-1-06 TR-64 Review Memo.doc <br />Attached is my draft review memo. The revised sections actually represent quite an improvement over the previous <br />version of the permit, but made it practicable to do a more detailed review (you might even think too detailed). <br />The biggest issue is addressed in Item 13, and pertains to the use of "technical standards" for cover and production <br />success criteria. The approach is technically not allowed by our regulations, but has been approved at New Horizon for <br />reasons addressed in the permit (and noted in Item 13). In this TR, they are requesting that the production success <br />standard for certain areas be lowered (for the second time). Our choices would be to; 1, retain the current (regulatorily <br />unauthorized) standard, which they probably will not be able to meet; 2, approve their proposed (regulatorily unauthorized) <br />standard, which they might be able to meet, and for which they have provided documentation similar to that provided <br />previously in support of the current standard; or 3, request that they investigate lease or purchase of suitable lands in the <br />permit vicinity to serve as reference areas or to derive a historic record standard (approaches which we could properly <br />approve under our current regulations). They will no doubt balk (and squeal loudly) if we make this request, but that is the <br />approach I have taken in the draft Item 13 comment. There is probably a good chance that, even if they agree to perform <br />the search for areas that would be suitable for reference sites or to derive historic record standards, they will ultimately <br />report back that there are no such sites or farmers willing to negotiate terms that would allow WFC the necessary <br />management controls. Maybe at a minimum, there would be some benefit to have them go through that exercise and <br />document it in writing. <br />I've taken this review about as far as I can take it, and will defer to the two of you at this point to finalize it as you see fit. I <br />will be in the field the rest of this week, then on annual leave, returning on Monday, Nov. 20. <br />Later... <br />11-1-06 TR-54 <br />ieview Memo.tloc .. <br />