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reflects management during the last several years. A portion of Ga-vey's hay fields <br />were renovated in 1986 and herbicides were applied to control persistent perennial <br />weeds such as Canada thistle and quackgrass. The fields have not been fertilized <br />for several years, some areas of shallow or boggy soils occur in part of fhe fields, <br />alfalfa composition in some of the older fields is low, and the hay fields were grazed <br />during the winter and into the early growing season. These factors all combined to <br />reduce production below the potential in Ganrey's fields. <br />In summarizing the type, varying site characteristics, individual management <br />objectives, ll applied management, and number of cuttings, result in wide ranges in <br />production for the type. Based on the 1987 field data collection, only one operator at <br />this time manages for sustained production during the growing season that <br />approaches the potential of the site. <br />Overall, the management is less than ideal in the permit area. <br />8) WFC has had considerable experience in side roll irrigation over the last 14 years. <br />The timing of the irrigation, water needed for the side roll, acreage that can be <br />covered, management intensity, etc. have been evaluated in detail. Based on this <br />information, which has been discussed with Jim Boyd of the NRCS, WFC believes <br />that the appropriate ratio of a share of the West Lateral of the CC Ditch is 0.8 to 1.2 <br />acre per share. This number is also highly dependent upon the management level of <br />the irrigation. As described in Item 7 above, the pre-mine management level was <br />mediocre. For irrigated alfalfa, WFC believes that the ratio is approximately 0.8 acres <br />per share. For irrigated grass, the ratio is 1.2 acres per share. Based on the pre-mine <br />irrigation practices of flood irrigation, WFC believes that the pre-mine ratio is even <br />lower than 0.8 acres per share. Documentation of this information is included as <br />Attachment A -Irrigation Calculations. <br />9) As pointed out in the DRMS memo from Dan Mathews in November, 2006, water <br />availability for sustaining long term irrigation on a reclaimed property should be <br />demonstrated. WFC agrees. The value of 1.0 acre per share(for pressurized <br />systems) is used as an average to determine the amount of land that should be <br />returned to irrigation for the reclaimed lands west of 2700 Road. The attached Map <br />2.05.4-5 Post Mining Land Use and Vegetation shows the landowners on the west <br />side of the permit and the associated water shares that are tied to those parcels. The <br />following discussion is presented for each individual parcel west of 2700 Road: <br />Benson West Parcel: The parcel of 38.97 acres immediately north of BB Road and <br />west of 2700 Road owned by Benson. <br />This tract was originally dass~ed by Peabody Coal as Irrigated Pasture. <br />This 39 acre tract was "Wild Flood Irrigated° in the past. That is to say, there <br />were no furrows, gated pipe, side roll sprinkler system or other methods to <br />control water distribution. Irrigation water was allowed to traverse over the <br />land at will. <br />Page 5 of 10 <br />