2010-02-18_REVISION - C1981008 (3)

Home Browse Search

?- C3S c.? I n-, J 1 Z? r? C-1981-008 PR-06 PAR 22-Jan-2010 • ,Page 22 of 26 71 acres of the Morgan property during the th MO an ro e liability period, with the reinder rat C t` ?? r 61. The PR-6 application roposes to of ndythe success standards and methods fo ?? demonstration of success on Prime Farmland irri gated alfalfa cropland in subsection 6.1 Of Section 2.05.4(2)(e). A reference field based standard is proposed to replace the currently approved technical standard. The current standard is based on estimated 1$` cutting hay crop yields provided by, three of the larger farmers in the mine area, and has been reviewed and deemed acceptable by MRCS. The proposed standard is referred to as a reference area in the narrative, but would actually be a designated field located on the same soil type, planted to thetsame, crop and subject to the same management as the reclaimed cropland, where 1 cutting hay production data would be collected for a minimum three year period to establish a production success standard (the average reference field production for the minimum 3 year period). The proposed standard would still be considered a technical standard rather than a reference area, since the three years of data collection from the reference field would not necessarily coincide with the three years of data collection from the reclaimed cropland. The proposed standard is a more objective approach than the existing standard, due to the fact that the.standard would be based on well documented site specific crop production data collected from an adjacent undisturbed site with the same soil types and management as the reclaimed area. We • have the following comments and questions regarding the proposed irrigated. cropland revegetation success standards and associated success demonstration approaches set forth in subsection 6.1. a) The Division understands that use of the proposed reference field as a true reference area may not be practicable, because "the Morgans cannot guarantee that this, reference area will be consistently irrigated and cropped in the future in the same manner as the reclaimed area." We believe it would be appropriate to collect production data from the reference field for a period longer than 3 years; to the extent that the reference area management remains consistent with reclaimed area management, in order to obtain the best possible long term average for use in success comparison. Further, if the reference field management is consistent with reclaimed area management during years corresponding to reclaimed area bond release sampling, success demonstration' should be based on comparison of reference field data to reclaimed data for that specific 3 year period (i.e.>a true reference area comparison). Please revise the pertinent narrative to address these requests. b) MRCS commented in their December 8, 2009 letter, on the importance of ensuring that alfalfa stands in the reference and reclaimed fields are similar. in age. P1,99se address within the pertinent narrative how records will be maintained for both =the reference and reclaimed areas to document stand. age, and how data used for success demonstration purposes will be screened to ensure that success standards reflect proper consideration of stand age.