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C- 1981 -008 August 25, 2010 <br />PR -06 AR#5 Page 15 of 26 <br />There is also confusion regarding seedmix and rates for the green manure crop and <br />companion crop. In Subsection 5.3, it is stated that the green manure crop would be oats at <br />75#/ac or Quickguard at 20# per acre, along with yellow sweetclover at 2# per acre. Would <br />Quickguard at 20# per acre be expected to provide the same quantity of green manure <br />biomass as oats at 754 per acre? Please provide validation for the Quickguard rate and revise <br />if warranted. <br />Regarding the companion crop, oats and Quickguard are listed as options. In the first <br />paragraph of Subsection 5.3, narrative indicates Quickguard would only be applied in the <br />fall; whereas a footnote to Seedmix 7 later in the subsection indicates that the Quickguard or <br />oats would be used as a companion crop when alfalfa planting occurs in the fall, which <br />would seem to imply that if Seedmix 7 were seeded at some other time, alfalfa would be <br />seeded alone, with no cover crop. Based on the schedule presented in Subsection 5.7.1, <br />Seedmix 7 would only be seeded at one time of year ( "around August "), so it is not clear why <br />the seasonal options are included in Subsection 5.3. The seeding rate listed for oats as a <br />companion crop to alfalfa in Seedmix 7 is listed as 75 lbs PLS per acre. This is incorrect; it <br />should be 20 lbs /PLS per acre. Please clarify and revise the companion crop narrative, <br />seeding rates, and seedmix footnote as warranted. Unless optional timeframes for seeding of <br />Seedmix 7 are set forth in Subsection 5.7.1, with proper validation, the caveat regarding <br />seasonal limitations for the companion crop would seem to be moot, and should be <br />eliminated to avoid any confusion. <br />The seeding methodology description presented in the next to last paragraph of amended <br />Subsection 5.4, still mentions "species of grass" in reference to the seeding. Alfalfa is the <br />crop species planted in Seedmix 7, and the green manure crop includes yellow sweetclover, <br />neither of which is a grass. The reference should be simply to "planted species" rather than <br />"species of grass ". Much of the detail that was deleted from the previous version of the <br />paragraph including use of either a cultipacker or drill seeder (with specific capabilities) was <br />appropriate, and should be restored, unless appropriate explanation is provided. Unless <br />broadcast seeding would be employed for use on cropland Seedmix 7 or the green manure <br />crop, the reference to use of broadcast seeding should deleted. Broadcast seeding does not <br />provide "the greatest level of success in terms of proper seed placement and firming of the <br />soil around the seed ". If broadcast seeding is retained, please confirm MRCS and landowner <br />concurrence, and address measures that would be used to cover the seed. <br />vi. The Division requested modifications to the "Quality Standard" for irrigated cropland in <br />Subsection 5.5.2, and the subsection was updated as requested. However, we request one <br />minor modification. In the first sentence of the "Quality Standard" description, please <br />replace county listed noxious weeds with permit listed noxious weeds, for consistency <br />with other permit sections. <br />vii. The Division requested a minor clarification to narrative in Subsection 5.5.3 to clarify <br />sample adequacy requirements with respect to small bale "in field" measurements. Item <br />Resolved <br />viii. The Division requested clarification to narrative in Subsection 5.5.3 to clarify sample <br />adequacy requirements with respect to large bale truck scale measurements. Item <br />Resolved <br />ix. The Division requested revision of narrative in Subsection 5.5.4 to comply with the time <br />frame requirements of Rule 4.25.5(3)(a). As the Division pointed out, the rule provision <br />