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C-1981-008 July 23, 2010 <br />PR-06 Page 19 of 31 <br />mechanical harvest for hay. Please amend the narrative for clarification regarding <br />proposed grazing practices on reclaimed IP areas. Specifically, address in more detail <br />whether livestock grazing would be conducted during the growing season on <br />reclaimed IP areas, and measures that would be taken to ensure proper grazing <br />management. Further clarify that during years in which sampling is conducted for <br />bond release, grazing would be deferred until after sampling is completed. Finally, <br />include a notation after the sentence regarding duplication of reclaimed area grazing <br />on the reference area, to clarify that in situations where the reclaimed area is harvested <br />for hay during the growing season, the reference area would be grazed in a manner to <br />mimic the mechanical harvest as closely as practicable. <br />Subsection 5.0 Revegetation - Irrigated Cropland (IC). <br />e. Subsection 5.2 addresses irrigation designs for the Morgan property. <br />i. The last fragmented sentence in the first paragraph should be deleted ("Referenced but <br />not scanned"). <br />ii. Narrative indicates that "old Morgan field labels" are shown on Map 2.05.4-5, but this <br />does not seem to be the case. The pre-mining Morgan fields do not belong on Map <br />2.05.4-5. Please remove them from that map. The proposed post mining Morgan <br />fields are appropriate on Map 2.05.4-5 as currently shown. Please remove the <br />premining fields from the map and legend and add the Morgan post-mining field <br />symbol to the legend. The Morgan field boundary symbol must be different than the <br />symbol for irrigation pipeline. <br />iii. 'We note that on Map 2.05.4-5, proposed gated pipe locations for irrigation of the two <br />flood irrigated fields on the Morgan field do not seem to be depicted, please provide <br />this detail on the map. <br />f. The first paragraph in Subsection 5.3 references personal communication with T. Doherty <br />for the recommended alfalfa seed mix. It's not clear what seed mix is being referenced and <br />who T. Doherty is. Furthermore, the Morgans have a specific alfalfa variety they are <br />requesting. Please clarify and/or delete the communication with T. Doherty. <br />g. Subsection 5.4 discusses the irrigated cropland seeding procedures. <br />i. Please move the discussion for seeding green manure from page 58 to the first step in <br />this subsection. <br />ii. In the second paragraph, confirm and use consistently the correct seeding rate for the <br />annual companion crop to be seeded with the alfalfa. Is this a fertile variety of <br />Triticale or the sterile Quickguard? Was the Triticale variety recommended by NRCS <br />for the cropland companion crop? Is it acceptable to the Morgans? In the past, NRCS <br />has recommended an oats companion crop at a rate of 20 lb/acre PLS. Seed Mix 7 <br />(Irrigated Cropland) lists 25 pounds PLS for the Triticale, but in 5.4 narrative and <br />53.1 narrative, WFC lists a rate of 40 pounds PLS for the Irrigated Cropland Triticale <br />companion crop seeding rate. Unless justification is provided, please consistently <br />specify use of oats at 201bs/acre PLS for the irrigated cropland companion crop to <br />alfalfa. <br />iii. Subsections 5.4 and 5.7.1 conflict. Please make sure to use the correct seeding rate <br />and time for seeding in all sections. Preferably, present the detailed rates, methods,