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~• ! <br />The bottom line is that CC-Ditch Company, with one of the oldest and most secure water rights <br />in the State of Colorado, consistently delivers water from the San Miguel River that adequately <br />meets share-holders irrigation demands. <br />Another very important point needs to be made at this time. The New Horizon Mine is required <br />to meet an established crop production goal in order to be released from its reclamation bond. <br />That yield goal, 1.84 tons/acre first cutting of alfalfa on Banc Fine Sandy Loam Soil, is an <br />average based on long-term yields of local farmers and documented by the United States <br />Department of Agriculture. By its very nature, the average of historic yields accounts for "good <br />water years" and "bad water years." Moreover, the part of the growing season that produces <br />first cutting, May and June, is normally the time of year when the CC-Ditch Company has had <br />little problem delivering the amount of irrigation water required for our three sideroll sprinkler <br />system to irrigate 70 acres of alfalfa sufficiently. August can be a problem month regarding <br />supplies of imgation water due to the fact that flows in the San Miguel River naturally decline, <br />but that has been the case for eons, and the long-term average of yields reflects this reoccurring <br />event. <br />Given the above discussion, Mr. Gubka's analysis of the CC-Ditch flow data is at best the result <br />of lack of knowledge regarding the irrigation needs of alfalfa, and at worst a complete <br />misrepresentation of the data. Irrigating and growing an agricultural crop is as much an "art" as <br />it is a science, and one has to adapt their management practices to the growing conditions that are <br />presented. The United States Department of Agriculture uses historical climate data as a starting <br />point for scheduling irrigation events, but it does not replace the need to monitor soil moisture in <br />the top 18 inches of the soil profile to get a "feel" for when it is time to irrigate the crop and how <br />much water to apply. <br />I will once again go on record as saying that 50 shares of CC-Ditch Company water is sufficient <br />to adequately irrigate 70 acres of alfalfa growing in Bari Fine Sandy Loam Soils in Nucla, <br />Colorado, using the three sideroll sprinkler system as I have designed. <br />Sincerely, <br />Jim Boyd, MRCS Resource Conservationist <br />cc. Western Fuels -Colorado <br />Morgan Family <br />