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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
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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 20 of 31 <br />and timing in a single section, and with references in other sections as warranted. <br />Repeating the details in different sections continues to cause problems. <br />iv. Does the temporary seed mix #3 apply to irrigated cropland? If so, revise wording in <br />Subsection 5.4 to replace "irrigated pasture" with "irrigated cropland". If not, please <br />remove the Seed Mix #3 references from Subsection 5.4. <br />V. Does the discussion regarding broadcast seeding of the grass seed in Subsection 5.4 <br />apply to irrigated cropland? If not, please remove the discussion. In general, the <br />wording of the 3rd paragraph of Subsection 5.4 seems to apply more to pastureland <br />seeding practices than to seeding practices for the irrigated cropland. Please amend as <br />appropriate, with specific seeding methods described for seeding of the green manure <br />crop and Seed Mix 7 (alfalfa and companion crop). Seed Mix 2 (Year 7 Annual Small <br />Grain) seeding method should be described in Subsection 5.7. <br />vi. The "Quality Standard" presented in the last paragraph of Subsection 5.5.2 should be <br />revised, given the fact that the crop produced on the irrigated cropland is alfalfa hay. <br />Also, given the fact that the cropland is prime farmland, the quality standard should <br />reflect the higher management levels associated with the prime farmland designation. <br />Please revise the first sentence of the paragraph to state: At least 85% of the relative <br />production will be comprised of alfalfa, and no more than I % relative production will <br />be comprised of county listed noxious weeds. Please delete the second sentence, since <br />production success is based on total harvest (such that weeds could not be excluded), <br />and cover is not applicable to cropland. Please revise the last sentence of the <br />paragraph to state: For the purposes of this demonstration, a statistically adequate <br />production sample of at least 15 clipped quadrats will be taken from the cropland <br />bond release block just prior to P cut harvest, with alfalfa and county listed noxious <br />weeds bagged, oven dried, and weighed separately from other species. Alternatively, <br />the quality standard can be demonstrated based on a written evaluation from visual <br />assessment by a qualified vegetation or agronomy professional, stating the <br />professional opinion that alfalfa production in the subject bond release block is at <br />least 85% of the total vegetation production, and noxious weed component is less than <br />1 % of the total vegetation production. The statement of professional opinion will be <br />accompanied by a signed statement of concurrence from the landowner. <br />vii. Subsection 5.5.3 addresses the hay harvest measurement method that would be used to <br />demonstrate irrigated cropland production success. Two alternative methods are <br />presented for hay production measurements. Option A applies to small bales (less <br />than 100 pounds), and would employ field sampling, in which a minimum of 15 bales <br />from the bond release field would be individually weighed using a field scale. <br />Sampling would continue until sample adequacy is demonstrated. Using average bale <br />weight thus obtained, total field production in pounds per acre would be calculated, <br />based on total bale count and field acreage. Option A is an acceptable method; <br />however two corrections need to be made. First, the word "may" in the 3rd sentence <br />following the sample adequacy formula should be changed to "will" (Sampling will <br />continue if necessary to reach sample adequacy...). Second, the final sentence of the <br />next to last paragraph of the subsection should be deleted (Alternative procedures will <br />require ...), since alternative statistical procedures for success demonstration would <br />not be applicable in this situation. <br />viii. The Option B hay production measurement approach described in Subsection 5.5.3 <br />applies to large bales (over 100 pounds). The large bale approach would involve
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