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Westmoreland Orchards fruit crop production data for 1977 through 1980, and reference to <br />possible establishment of success standards based on theoretical fruit crop yields as a <br />function of time. <br />Planting of fruit trees in orchard cropland areas is also referenced in the second paragraph of <br />page 82 of the Reclamation Plan. <br />Irrigated Grass Hay Croplan <br />d <br />Permit Volume 7 is a comprehensive operation and reclamation plan for the loadout, which <br />was apparently submitted as a technical revision in 2001. The revegetation plan presented in <br />Section 2.05.4(2)(e)(ii) entails planting of a "premium irrigated pasture mix" of brome, <br />orchardgrass, and perennial ryegrass. The plan includes a generalized irrigation plan <br />involving sprinkler irrigation initially and flood irrigation following grass establishment. <br />The plan mentions fertilizer application prior to seeding, and states that amount and type of <br />topsoil is unknown. The narrative also indicates that success would be based on production <br />measured in an adjacent hayfield reference area, but it is not evident that such reference area <br />has been secured, approved, and incorporated into the permit. <br />Confusingly, there is an Exhibit 5 included in Volume 7, which refers to plans for orchard <br />reestablishment and the potential time/yield approach for establishment of a success <br />standard. <br />In summary, the revegetation plan for the loadout cropland postming land use area is <br />confusing, contradictory, and poorly defined. Submittal of a technical revision application <br />to clarify the proposed loadout revegetation plan and eliminate outdated information is <br />warranted. The application will need to provide additional detail regarding topsoil <br />acquisition and replacement, or alternatively, a plan for amendment (e.g. fertilizer and <br />organic matter incorporation) of on-site materials to provide a productive agricultural <br />growth medium. In addition, the plan will need to address management details with respect <br />to annual irrigation and fertilization rates, irrigation layout, harvest methods, tillage <br />operations, weed and pest control, fencing, and other practices consistent with prudent crop <br />management in the region. Area NRCS and/or CSU county agricultural extension service <br />recommendations will need to be or obtained and documented, with respect to prudent <br />management practices. An appropriate reference area site or other success standard <br />approach will need to be identified, demonstrated to be appropriate, and incorporated into <br />the permit, along with details regarding comparisons to be made to demonstrate success. <br />Please provide a commitment within the TR-48 response materials, to provide a <br />comprehensively revised reclamation plan for the cropland land use areas at the <br />Paonia Loadout, which will address soil replacement or amendment plans, detailed <br />planting and liability period management plans, revegetation success standard, and <br />methods of comparison for demonstration of success. The commitment will need to <br />specify submittal of a complete technical revision application by September 30, 2008. <br />5