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2 ' <br />C -1981 -008 22 -Jan -2010 <br />PR-06 PAR <br />0 'I�Page 22 of 26 <br />L 71 <br />acres of the Morgan property during the liability period, with the re finder <br />Mo an roe ' <br />ANQ <br />61. The PR -6 application roposes to al =the success standards and methods for <br />demonstration of success on Prime Farmland irrigated alfalfa cropland in subsection 6.1 <br />of Section 2.05.4(2)(e).; A reference field based standard is proposed to replace the <br />currently approved technical standard. The current standard is based on estimated 1 st <br />cutting hay crop yields provided by three of the larger farmers in the mine area, and has <br />been reviewed and deemed acceptable by MRCS. The proposed standard is referred to as <br />a reference area in the narrative, but would actually be a designated field located on the <br />same soil type, planted to the same crop and subject to the same management as the <br />reclaimed cropland, where 1 cutting hay production data would be collected for a <br />minimum three year period to establish a production success standard (the average <br />reference field production for the minimum 3 year period). The proposed standard would <br />still be considered a technical standard rather than a reference area, since the three years <br />of data collection from the reference field would not necessarily coincide with the three <br />years of data collection from the reclaimed cropland. The proposed standard is a more <br />objective approach than the existing standard, due to the fact that the standard would be <br />based on well documented site specific crop production data collected from an adjacent <br />�• undisturbed site with the same soil types and management as the reclaimed area. We <br />have the following comments and questions regarding the proposed irrigated_ cropland <br />revegetation success standards and associated success demonstration approaches set forth <br />in subsection 6.1. <br />a) The Division understands that use of the proposed reference field as a true reference <br />area may not be practicable, because "the Morgans cannot guarantee that this reference <br />area will be consistently irrigated and cropped in the future in the same manner as the <br />reclaimed area." We believe it would be appropriate to collect production data from the <br />reference field for a period longer than 3 years, to the extent that the reference area <br />management remains consistent with reclaimed area management, in order to obtain the <br />best possible long term average for use in success comparison. Further, if the reference <br />field management is consistent with reclaimed area management during years <br />corresponding to reclaimed area bond release sampling, success demonstration' should be <br />based on comparison of reference field data to reclaimed data for that specific 3 year <br />period (i.e. a true reference area comparison). <br />PIease revise the pertinent narrative to address these requests. <br />b) MRCS commented in their December 8, 2009 letter, on the importance of ensuring that <br />alfalfa stands in the reference and reclaimed fields are similar -in age. <br />Pltase address within the pertinent narrative how records will be maintained for <br />1. both the reference and reclaimed areas to document stand, age, and how data used <br />for success demonstration purposes will be screened to ensure that success <br />standards reflect proper consideration of stand age. <br />