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C- 1981 -008 <br />PR -06 AR #5 <br />August 25, 2010 <br />Page 14 of 26 <br />ix. The Division requested a number of modifications to narrative in Subsection 4.6, to <br />clarify planned livestock grazing management of reclaimed IP areas during the liability <br />period. The requested narrative modifications were provided. We note, however, that <br />liability period irrigation management associated with reclaimed IP areas is not <br />addressed, and Subsection 4.6 would be the appropriate place to include such discussion. <br />Please address irrigation scheduling and management throughout the growing season, as <br />impacted by yearly variations in weather, ditch water turn-out date, single or multiple <br />annual cuttings, livestock grazing, etc. Also, please include a reference to the subsection <br />of 2.05.4(2)(d) that addresses liability period fertility management. Finally, provide the <br />correct Attachment reference for the MRCS letter referred to at the end of Subsection 4.6. <br />Subsection 5.0 Revegetation - Irrigated Cropland (IC). <br />The Division notes there were quite a few changes to the seedbed preparation, seeding and time frames <br />for Morgan prime farmland that were not prompted by our adequacy comments. Some of those changes <br />may have been requested by the landowners, but that is not clear. That section had previously been <br />close to approval, but now it is full of conflicting information and vague language. This type of <br />submittal creates undue delays in our review. In the future, the Division requests that WFC explain and <br />identify in the cover letter any changes that have been made beyond what is requested in the adequacy <br />letter. Furthermore, if WFC is proposing changes to one section, it is imperative that those changes <br />remain consistent with narrative in other sections of the permit. Please cross -check to ensure <br />consistency in the application. <br />e. Subsection 5.2 addresses irrigation designs for the Morgan property. <br />L A typographical error was corrected. Item Resolved <br />ii. Map 2.05.4 -5 field labels and boundary lines were modified as requested. Item Resolved. <br />iii. Map 2.05.4 -5 was revised to depict gated pipeline locations. Item Resolved <br />f. The first paragraph of Subsection 5.3 was reworded to delete outdated references, as <br />requested. Item Resolved <br />g. (i through v) <br />In this item, the Division had numerous questions regarding seeding procedures and seeding <br />rates, and conflicting information regarding such in various subsections. Information in <br />Subsections 5.3, 5.4, and 5.7 was revised, in part to address the Division's questions, and <br />apparently also in part to incorporate landowner requests. Inconsistencies remain and we <br />have a number of questions and requests. <br />There is confusion regarding the timing of various seedings. In Subsection 5.3, narrative <br />indicates that Mix 7 (alfalfa plus companion crop) would be applied in the fall of Years 1 and <br />7, with initial seeding of green manure crop in spring of Year 1. Subsection 5.4 indicates <br />Mix 7 would be seeded in June, and green manure crop would be planted "prior to August <br />21 ". In Subsection 5.7, green manure crop would be seeded in spring of Year 1, and would <br />be plowed up prior to planting of Mix 7 "around August ". To eliminate this confusion, <br />please consolidate all seeding timeframe specifications in Subsection 5.7.1, with planting <br />dates for particular seedmixes listed only one time. Replace generalized references such as <br />spring, fall, or "around August ", with specified calendar windows (in accordance with NRCS <br />recommendations and landowner requests). <br />