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multiplying the total number of bales counted in afield by the average <br />adjusted bale weight and dividing by the size of the field in acres. <br />Obtaining fresh weight and dry weight subsamples in the manner described in <br />order to derive an adjustment factor would seem to be important in order to ensure <br />an "apples to apples" dry weight based comparison of reclaimed area and <br />reference site production. Please amend the yield determination procedure in <br />subsections 6.1.3 and 6.1.4 to address subsample collection, weighing and <br />drying, and derivation of "dry weight adjusted" bale weights consistent with <br />the 1987 baseline procedure, for use in production success comparisons. <br />d) The production success demonstration approach proposed is in essence a total <br />harvest method, since the entire reference field and the entire bond release field <br />would be mowed and baled. The sampling component of the demonstration <br />would be limited to weighing an adequate number of randomly selected bales to <br />establish an accurate average bale weight, with sub-sampling of the selected bales <br />to establish an appropriate fresh/oven dry adjustment factor. The bond release <br />area adjusted production (avg. adj. Bale wt. * number of bales divided by acreage) <br />would be determined for each of the three sampling years and the 3 year average <br />adjusted production would be compared to the appropriate 3 year (+) average <br />adjusted reference field production determined in the same manner. Given the <br />fact that the approach is a modified total harvest involving comparison of <br />averages derived from harvest data collected over multiple years, much of the <br />sampling and statistical detail provided in sub-section 6.1.4 would seem not to <br />apply. <br />We recommend that the 3'd sentence following the sample adequacy formula be <br />amended to state "Sampling will continue as necessary to reach sample adequacy. <br />The remainder of the sentence should be deleted. The following paragraph <br />beginning with "Reclaimed area production will be compared..." should be <br />revised to correspond to the approach described in the 3rd sentence of the previous <br />paragraph in this item 19d. The remaining text and formulas in amended <br />subsection 6.1.4 should be deleted. <br />Please revise the subsection as requested, unless justification for an <br />alternative approach can be provided. <br />e) We believe there are several erroneous components in the production success <br />standard as summarized in the first paragraph of amended sub-section 6.1.5. <br />First, there is reference to use of tons per acre for the success comparison. The <br />level of precision is not specified, but production success is typically evaluated in <br />pounds per acre. Second, the statement indicates that success would be <br />demonstrated if reclaimed area production is equal to or greater than the standard <br />in "at least 3 of 5 years". The basis for this is not clear; Rule 4.25.5(3)(c) states <br />that success will be demonstrated "...when the adjusted 3 year average annual <br />crop production is equivalent to, or higher than, the average yield of the reference <br />11