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C-1981-008 July 23, 2010 <br />PR-06 Page 21 of 31 <br />loading of bales onto a truck and weighing at a certified truck scale. It is not entirely <br />clear from the narrative whether Option B would involve weighing all bales from the <br />bond release field, or whether a minimum of 15 bales would be individually unloaded <br />and. weighed at the certified truck scale, with sample adequacy and total field <br />production determined as described for small bales under Option A. Note that sample <br />adequacy could not be demonstrated by weighing a single truck load of 15 large bales. <br />Either method would be acceptable (weighing all bales in the field, or weighing a <br />statistically adequate sample of individual bales), but the narrative for Option B needs <br />to be revised to provide this clarification. <br />ix. Subsection 5.5.4 addresses revegetation success criteria and statistical procedures for <br />irrigated cropland. The final paragraph of the subsection describes an approach WFC <br />would undertake if the 3 year production average (based on Year 9, 10, and 11 data) <br />does not meet the 1.84 ton per acre standard. The WFC proposed approach would <br />entail collecting data for Year 12, with the "best 3 out of 4" production years used to <br />obtain the average for comparison to the technical standard after Year 12. If that <br />average did not meet the standard, Year 13 harvest data would be collected, and the <br />"best 3 out of 5" production years would be used to obtain the average for comparison <br />to the standard. The "best 3 out of 4" or "best 3 out of 5" approaches do not comply <br />with Rule 4.25.5(a), which requires that average annual crop production shall be <br />determined based upon a minimum of 3 years of data, and that "crop production shall <br />be measured for the three cropping years immediately prior to full release of the <br />bond...". As such, if Year 12 data is obtained, the average for comparison to the <br />standard could be based on Years 9 through 12, or Years 10 through 12. Similarly, if <br />Year 13 data is obtained, the average for comparison to the standard could be based on <br />Years 9 through 13, or Years 11 through 13. Please revise the wording of the final <br />paragraph of Subsection 5.5.4 to comply with Rule 4.25.5(a). <br />X. Subsection 5.7.1. Refer to the seed mixes in Subsection 5.3 using the correct rates. <br />Revise or confirm appropriate companion crop as requested in regard to the seedmix <br />listed in Subsection 5.3 and conflicting narrative in Subsection 5.4. <br />Subsection 6.0 Revegetation - Dryland Pasture (DP) <br />h. In Subsection 6. 1, please correct the first sentence of third paragraph. In Subsection 6.2 <br />after Seed Mix #8, please update the reference to "Soil Conservation Service" with "Natural <br />Resources Conservation Service". <br />i. In Subsection 6.3, please address the seeding method and timing to be used for forage <br />kochia. Also please confirm that the drill seeder used for Seed Mix 8 will be capable of <br />seeding directly into the untilled stubble mulch crop. <br />j. Certain narrative changes in the final paragraph of Subsection 6.4, seem questionable. The <br />statement that "during grazing rotations within the irrigated pasture types, there is potential <br />for periodic heavy concentrations of grazing animals" was deleted. In the following <br />sentence:, "grazing pressure" was replaced with "natural grazing pressure". These changes <br />imply that the dryland pasture areas would not be grazed by livestock and would not be <br />subject to periodically heavy grazing pressure from livestock. However, over the long term <br />following bond release, it is likely that such livestock grazing will occur, even if there is <br />minimal or no livestock grazing on the dryland pastures during the liability period. Please <br />amend the section as appropriate.