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Mr. Ross Gubka, P.E. <br />Western Fuels-Colorado <br />December 11, 2007 <br />Page 2 <br />any), as well as items that were addressed within the TR-55 submittal, and <br />Items addressed within the TR 56 submittal. Include reference to associated <br />text, tables, maps, or appendices, along with the applicable page or map <br />revision date. If a particular page or exhibit was amended more than once, <br />please identify the most recently amended version of the document, which <br />would supersede previous versions. <br />2. There are discrepancies with regard to postmine vegetation type acreages among <br />TR-55 amended versions of Table (e)-1, Map 2.05.4-5, and pages (e)-6, (e)-7, and <br />(e)-19. Please ensure that the correct acreages are listed, that the various <br />listings are consistent, and that the individual type acreages add up to the <br />total permit acreage (the acres listed on amended pages (e)-6 and (e)-7 sum to <br />821.61; not the 823.56 acres indicated). <br />On TR-55 amended page (e)-7, there is a statement in the first paragraph <br />indicating that the property owner (Morgan) historically re-plowed his irrigated <br />hay cropland from time to time, "and the same practice may be employed after <br />reseeding". The implication that re-plowing (and presumably full reseeding) <br />would be undertaken periodically during the liability period conflicts with a <br />statement on amended page (e)-9 indicating that "interseeding of Cropland- <br />Irrigated Grass Hay, may occur throughout the bond release period, as this is a <br />normal husbandry practice". Appropriate documentation supporting interseeding <br />was provided on the following page from Jim Boyd, Resource Conservationist <br />with the MRCS. Mr. Boyd's letter defines interseeding as application of seed to <br />an existing field without mechanical soil preparation, and the letter focused <br />primarily on interseeding of legumes into a grass dominated stand. Mr. Boyd's <br />letter does not support re-plowing and full reseeding as a normal husbandry <br />practice. <br />To conform with the normal husbandry practice documentation provided by <br />NRCS, please delete the statement on page (e)-7 indicating that re-plowing <br />may be employed after reseeding, and clarify on page (e)-9 that interseeding <br />of Cropland-Irrigated Grass Hay with alfalfa to improve or maintain the <br />legume component may be periodically conducted during the liability period. <br />4. In the second paragraph on amended page (e)-16, there is a statement indicating <br />that "irrigation design and application rates will be submitted to CDRMS for <br />concurrence". The design and application rate information is provided in the final <br />paragraph on the same page, and has been previously reviewed and accepted by <br />the Division. The commitment to provide the information would appear to be <br />outdated and could lead to confusion. Please delete the sentence stating that <br />"...irrigation design and application rates will be submitted..." <br />5. We have a number of requests and recommendations regarding details of the <br />sampling protocol and success demonstration procedures applicable to the