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Page 8: <br />Land leveling and rock picking is an important management activity for cropland/hayland and <br />should be considered in the reclamation process- <br />Page 9: <br />A broadcast seeding rate is double the drill rate, and therefore increased 100% over the drill rate. <br />Page 11: <br />Although an added expense, weed free mulch properly applied to a seeding can be areal benefit <br />for germination and establishment of the seeding. <br />Typically a companion crop of oats is planted at a rate of 20 lbs/acre in the spring with the <br />alfalfa. The oat crop provides quick ground cover to reduce soil erosion, control weeds, prevent <br />wind damage to young alfalfa seedlings, reduce soil crusting, and increase forage production <br />during the seeding year -- multiple benefits beyond just providing a cash crop to producers the <br />first year. The key is to not to seed the oats at too high a rate' <br />Pages 13 & 15: <br />Old varieties of alfalfa listed (Lahonton, Vernal, Ranger), are cold hardy but low producers; ok <br />for the grass dominated pastures. Ladak alfalfa is drought tolerant but also a low producer. <br />There are improved varieties on the market that are better producers for irrigated "Hayland." <br />Page14: <br />The drilled seeding rate for Seed Mix #7 is too high; it should be 8.3 lbs PLS/ acre.. More is not <br />always better and seeding rates can be too high. The goal is to get a certain number of plants <br />established per square foot. if too many plants germinate in a give area, which can happen with <br />excessive seeding rates, they will compete with each other for light, nutrients, and water, and <br />none will have a chance to reach full maturity. It's like having too many radishes germinate in <br />the garden, thinning has to occur before some can get big enough to eat. <br />Page 21: <br />As discussed above, "Irrigated Cropland Grass Hay = ICO" is really a fuzzy term. <br />We have producers in the area that grow straight alfalfa hay, rotated with other crops such as <br />com, oats, sorghumisudan grass, etc., on their better soils. This is intensively managed <br />cropland/hayland and should be recognized as such. Yes, irrigated grass hay is a common land <br />use in the area, but not the exclusive land use for what we call "Cropland." <br />Page 29: <br />If a production standard is utilized for bond release it needs to be based on long term data that <br />documents yields of local farmers per soil type per crop. Well managed alfalfa hay will produce <br />higher yields per acre than well managed grass hay, all other things being equal. Also, better <br />soils will naturally provide higher crop yields than soils with poorer chemical and physical <br />properties, all other things being equal. <br />Page 31: <br />The production factors developed by NRCS are suitable for production only, not cover. The <br />inherent fertility and depth of the soil, along with production records taken from the San Miguel <br />Soil Survey were used to establish the soil production factors. Cover, basal or canopy, is an <br />entirely different parameter, not necessarily dependent on the fertility of the soil, as is <br />production. I am not confident that production and cover are directly related, e.g., there are <br />circumstances were we can have good cover and poor production. <br />