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C- 1981 -008 PR -06 <br />PAR — Supplemental <br />06- Apr -2010 <br />Page 4 of 7 <br />during the liability period. Based on documentation from JoEllen Turner at the informal <br />conference and Jim Boyd's letter dated March 8, 2010, the MRCS has stated that, with <br />proper management, 97.5 acres of alfalfa could be irrigated on the Morgan property with <br />60 shares of CCC ditch water, using 4 sideroll sprinklers. Mr. Boyd noted that a <br />trapezoidal area of 11.5 acres in the south - central portion of the Morgan property could <br />not be irrigated using the subject sideroll design. (This acreage could only be irrigated by <br />other systems, and may require a commensurate increase in water above the 60 shares). <br />Please provide a plan to restore the maximum acreage of irrigated cropland on the <br />Morgan property based on the irrigation water available, the MRCS design <br />recommendations and additional relevant factors that can be documented with regard to <br />irrigation system capability. If there is a small acreage that cannot be irrigated, <br />designation of such acreage as Dryland Pasture would seem to be preferable to Potential <br />Cropland (see Item 12, above). <br />61. Item 61 and sub -items 61 a through 61 e of the PAR applied to a proposed Irrigated <br />Cropland reference site to be located on Morgan property outside the permit area. At the <br />informal conference, Ms. Turner indicated the Morgan family will not agree to WFC <br />using the site as a reference area. <br />As an alternative, in the March 16 meeting, WFC suggested using a smaller site located <br />directly adjacent to the reclaimed fields within the permit boundary on the Morgan <br />property that would be managed consistent with the reclaimed prime farmland cropland. <br />If this site were to be used, documentation demonstrating the acceptability of the site for <br />reference area use, including location, extent, soil type(s), present condition and <br />management, and planned management (including measures to ensure that reference area <br />management is consistent with reclaimed area management) would be necessary. <br />Documentation of NRCS concurrence for the reference site and any proposed soil factor <br />adjustments will be required. Methods of comparison to demonstrate revegetation <br />success pursuant to Rule 4.25.5 will need to be addressed, including measures that will be <br />taken to ensure that the stand age (years since renovation) are not biased in favor of the <br />reclaimed parcel during the required 3 year comparison period. A quadrat sampling <br />based success demonstration approach would likely be warranted rather than a bale count <br />method, due to lack of precision associated with the very small number of the large bales <br />that would be produced from such a small area. <br />After further consideration and discussions with the MRCS regarding potential problems <br />associated with such a small irrigated cropland reference area, the Division recommends <br />WFC maintain the currently approved technical standard of 1.84 tons /acre for the <br />revegetation success standard on irrigated cropland. Use of the technical standard would <br />eliminate any questions regarding the acceptability of the reference site and eliminate <br />future management issues. <br />