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identify the most recently amended version of the document, which would supersede <br />previous versions. <br />2. There are discrepancies with regard to postmine vegetation type acreages among TR-55 <br />amended versions of Table (e)-1, Map 2.05.4-5, and pages (e)-6, (e)-7, and (e)-19. Please <br />ensure that the correct acreages are listed, that the various listings are consistent, and <br />that the individual type acreages add up to the total permit acreage (the acres listed <br />on amended pages (e)-6 and (e)-7 sum to 821.61; not the 823.56 acres indicated). <br />3. On TR-55 amended page (e)-7, there is a statement in the first paragraph indicating that the <br />property owner (Morgan) historically re-plowed his irrigated hay cropland from time to <br />time, "and the same practice may be employed after reseeding". The implication that re- <br />plowing (and presumably full reseeding) would be undertaken periodically during the <br />liability period conflicts with a statement on amended page (e)-9 indicating that <br />"interseeding of Cropland-Irrigated Grass Hay, may occur throughout the bond release <br />period, as this is a normal husbandry practice". Appropriate documentation supporting <br />interseeding was provided on the following page from Jim Boyd, Resource Conservationist <br />with the NRCS. Mr. Boyd's letter defines interseeding as application of seed to an existing <br />field without mechanical soil preparation, and the letter focused primarily on interseeding <br />of legumes into a grass dominated stand. Mr. Boyd's letter does not support re-plowing <br />and full reseeding as a normal husbandry practice. <br />To conform with the normal husbandry practice documentation provided by NRCS, <br />please delete the statement on page (e)-7 indicating that re-plowing may be employed <br />after reseeding, and clarify on page (e)-9 that interseeding of Cropland-Irrigated <br />Grass Hay with alfalfa to improve or maintain the legume component may be <br />periodically conducted during the liability period. <br />4. In the second paragraph on amended page (e)-16, there is a statement indicating that <br />"irrigation design and application rates will be submitted to CDRMS for concurrence". <br />The design and application rate information is provided in the final paragraph on the same <br />page, and has been previously reviewed and accepted by the Division. The commitment to <br />provide the information would appear to be outdated and could lead to confusion. Please <br />delete the sentence stating that "...irrigation design and application rates will be <br />submitted..." <br />5. We have a number of requests and recommendations regarding details of the sampling <br />protocol and success demonstration procedures applicable to the "Cropland-Irrigated Grass <br />with Alfalfa Type (ICG)" beginning on amended page (e)-21. A number of the changes we <br />are requesting with respect to success testing procedures for the ICG type, are due to the <br />fact that ICG success testing is based on comparison of reclaimed area production to a <br />technical standard rather than a reference area. Given this fact, discussion of reference <br />area sample size and inclusion of two-sample testing procedures is not appropriate. Please <br />consider the following recommendations, and provide appropriate amendments. <br />2