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standard is a more objective approach than the existing standard, due to the fact <br />that the standard would be based on well documented site specific crop <br />production data collected from an adjacent undisturbed site with the same soil <br />types and management as the reclaimed area. We have the following comments <br />and questions regarding the proposed irrigated cropland revegetation success <br />standards and associated success demonstration approaches set forth in subsection <br />6.1. <br />a) The Division understands that use of the proposed reference field as a true <br />reference area may not be practicable, because "the Morgans cannot guarantee <br />that this reference area will be consistently irrigated and cropped in the future in <br />the same manner as the reclaimed area." We believe it would be appropriate to <br />collect production data from the reference field for a period longer than 3 years, to <br />the extent that reference area management remains consistent with reclaimed area <br />management, in order to obtain the best possible long term average for use in <br />success comparison. Further, if the reference field management is consistent with <br />reclaimed area management in the future during years corresponding to reclaimed <br />area bond release sampling, success demonstration should be based on <br />comparison of reference field data to reclaimed data for that specific 3 year period <br />(i.e. a true reference area comparison). Please revise the pertinent narrative to <br />address these requests. <br />b) NRCS commented in their December 8, 2009 letter, on the importance of <br />ensuring that alfalfa stands in the reference and reclaimed fields are similar in age. <br />Please address within the pertinent narrative how records will be maintained <br />for both the reference and reclaimed areas to document stand age, and how <br />data used for success demonstration purposes will be screened to ensure that <br />success standards reflect proper consideration of stand age. <br />c) Field harvest yield determination methods for reclaimed area and reference site <br />are addressed generally in subsection 6.1.3 and more specifically in subsection <br />6.1.4. Statements in both sections indicate that fresh bale weights would be <br />recorded in both reference and reclaimed sites, with no adjustment to dry weight. <br />However, subsection 6.1.4 narrative states that the harvest measurement method <br />would be consistent with the method used in 1987 to determine baseline <br />production. The 1987 methods are described in subsection 4.7 of Section 2.04.10. <br />With respect to drying, the procedure is detailed as follows: <br />At the time of weighing, sub-samples of hay were collected from a portion <br />of the bales, weighed using Pesola field scales, bagged and labeled, and <br />returned to the laboratory for analysis. In the laboratory, sub-samples <br />were dried at 30 deg. C for 72 hours, or until constant weight was obtained, <br />and re-weighed using an Ohaus top-loading electronic balance which is <br />accurate to 0.01 gm. This provided an adjustment factor needed to <br />determine dry weight production for the fields. The hay production in the <br />fields, expressed on a dry weight basis as pounds/acre, was calculated by <br />10