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2010-07-23_REVISION - C1981008
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2010-07-23_REVISION - C1981008
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Last modified
8/24/2016 4:16:46 PM
Creation date
7/26/2010 9:59:42 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
7/23/2010
Doc Name
Adequacy Review No. 4
From
DRMS
To
Western Fuels Colorado
Type & Sequence
PR6
Email Name
DAB
MLT
SB1
Media Type
D
Archive
No
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C-1981-008 July 23, 2010 <br />PR-06 Page 18 of 31 <br />heading (preceding Table 2.05.4(2)(e)-(2)) is somewhat repetitive and lacks clarity. <br />Please amend the paragraphs as follows: Delete the sentence in the 1St paragraph that <br />begins with "The table below... ". Delete the entire 2°d paragraph and insert the <br />following: Assignment of a relative production factor to each soil type allows for the <br />calculation of an acreage weighted relative production factor for the entire reference <br />area, and for an entire irrigated pastureland bond release block (based on the soil <br />types present in the bond release block prior to mining). Replace the sentence <br />immediately prior to Table (e)-(2) to with the following narrative: The table below <br />shows how the weighted average production factor for the reference area is <br />calculated. The same procedure is used to calculate a weighted average production <br />factor for an irrigated pastureland bond release block. Narrative following the table <br />explains how the weighted average factors are used to adjust the reference area <br />sample mean for bond release comparisons. The adjustment procedure elevates the <br />production success standard in situations where premining soils were on average <br />potentially more productive than reference area soils, and lowers the standard in <br />situations where premine soils were on average potentially less productive than <br />reference area soils. <br />vi. In the fourth sentence of the first paragraph following Table (e)-2, weighted average <br />adjustment factor should be changed to weighted average production factor. In the <br />fifth sentence of the paragraph, means should be changed to mean. <br />vii. The paragraph within Subsection 4.5.1 that addresses the timeframe for bond release <br />sampling should be modified to allow for year to year variation in timing of 1 st cut <br />harvest. We recommend that the last sentence of the paragraph be amended as follows: <br />Measurements will typically be made in late May to early June, although the <br />timeframe is subject to variation associated with weather conditions and irrigation <br />water availability. Sampling will be conducted within the two weeks prior to 1st cut <br />harvest of the reclaimed fields and prior to any growing season livestock grazing in <br />the reference area. <br />viii. Subsection 4.5.2 "New Reclaimed Irrigated Pastureland Reference Area" would more <br />appropriately be titled "Irrigated Pastureland Reference Area Characterization and <br />Management". The last sentence of the introductory paragraph should be changed to <br />state "A detailed discussion of reference area characteristics and management is <br />presented below." The narrative would be clearer if it were broken into two parts, with <br />the sub-headings "Reference Area Characterization" and "Reference Area <br />Management". The narrative under Item 5 should be presented in the first part of the <br />subsection under "Reference Area Characterization", with the item numbers deleted. <br />Items 3 and 4 could be incorporated into the initial part of the "Characterization..." <br />narrative, with the item numbers deleted. The narrative under Items 1 and 2 should be <br />presented in the second part of the subsection, under the sub-heading "Reference Area <br />Management", with the item numbers deleted. <br />ix. In Subsection 4.6, narrative indicates that after the first season, "grazing may be <br />implemented in the winter". This would seem to imply that grazing would not be <br />conducted on IP reclaimed areas during the growing season, but areas that are hayed <br />during the summer might be grazed during the winter. However, the following <br />sentence states that "Harvesting will continue to be considered as a management <br />option if grazing is not implemented in any given year." This would seem to imply <br />that grazing during the growing season might be conducted as an alternative to
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