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<br />Irrigated Grass Hay Cropland <br />Permit Volume 7 is a comprehensive operation and reclamation plan for the loadout, which was <br />apparently submitted as a technical revision in 2001. The revegetation plan presented in Section <br />2.05.4(2)(e)(ii) entails planting of a "premium irrigated pasture mix" of brome, orchardgrass, and <br />perennial ryegrass. The plan includes a generalized irrigation plan involving sprinkler irrigation <br />initially and flood irrigation following grass establishment. The plan mentions fertilizer <br />application prior to seeding, and states that amount and type of topsoil is unknown. The narrative <br />also indicates that success would be based on production measured in an adjacent hayfield <br />reference area, but it is not evident that such reference area has been secured, approved, and <br />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 standard. <br />In summary, the revegetation plan for the loadout cropland postming land use area is confusing, <br />contradictory, and poorly defined. Submittal of a technical revision application to clarify the <br />proposed loadout revegetation plan and eliminate outdated information is warranted. The <br />application will need to provide additional detail regarding topsoil acquisition and replacement, or <br />alternatively, a plan for amendment (e.g. fertilizer and organic matter incorporation) of on-site <br />materials to provide a productive agricultural growth medium. In addition, the plan will need to <br />address management details with respect to annual irrigation and fertilization rates, irrigation <br />layout, harvest methods, tillage operations, weed and pest control, fencing, and other practices <br />consistent with prudent crop management in the region. Area NRCS and/or CSU county <br />agricultural extension service recommendations will need to be or obtained and documented, with <br />respect to prudent management practices. An appropriate reference area site or other success <br />standard 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 Paonia <br />Loadout, which will address soil replacement or amendment plans, detailed planting and <br />liability period management plans, revegetation success standard, and methods of <br />comparison for demonstration of success. The commitment will need to specify submittal of <br />a complete technical revision application by September 30, 2008. <br />If you have any questions, please call me. <br />Sincerely, <br />tsepl. dash <br />Environmental Protection Specialist <br />cc: William A. Bear (Bowie Resources LLC) <br />c:\word\bowie 1 \tr48adeq I <br />4