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C -1981 -008 August 25, 2010 <br />PR -06 AR##5 Page 16 of 26 <br />specifies that crop production be determined based upon a minimum of 3 years of data, <br />and that crop production be measured for the three cropping years immediately prior to <br />bond release. The narrative as revised by WFC does not specify that the multiple years <br />of data used to determine the average crop production would include the three cropping <br />years immediately prior to full release of bond. Please revise the narrative of Subsection <br />5.5.4 to specify that calculation of the average crop production value used for <br />demonstration of crop production success would include the crop production values <br />determined for the three cropping years immediately prior to bond release, <br />x. The Division requested modifications to Subsection 5.7.1 to eliminate conflicts and <br />inconsistencies with seeding practices and seeding rates as listed in Subsections 5.3 and <br />5.4. Narrative was amended, but inconsistencies remain, and will need to be corrected <br />(see items i through v, above). In the 5.7.1 management sequence, Year 1 time windows <br />for seeding and disking in the green manure crop were eliminated, as was the reference to <br />irrigation application following Seedmix 7 initial seeding, to establish the stand before <br />winter. Unless a valid explanation for these changes is provided, please restore the <br />original detail for Year 1. <br />xi. We have an additional request regarding the Liability Period Management Plan outlined <br />in Subsection 5.7. Under the 5.7.1 Management Sequence for Years 2 -6 and 8 -11, it is <br />stated that the land would be irrigated and harvested according to normal management <br />procedures. Please provide a summary discussion under 5.7.4 Irrigation Management, of <br />the normal management sequence with respect to irrigation and management prior to first <br />cut harvest, and irrigation/harvest management subsequent to first harvest through the <br />end of the growing season. <br />Subsection 6.0 Revegetation — Dryland Pasture (DP) <br />h. An outdated reference to Soil Conservation Service was properly updated. A problem with <br />sentence syntax in the first sentence of the third paragraph of Subsection 6.1 was identified <br />by the Division but was not corrected. Please correct the sentence. <br />i. The Dryland Pasture seeding procedure in subsection 6.3 was amended to specify that forage <br />kochia would be broadcast seeded during the fall dormant season. Item Resolved <br />j. The Division requested clarifications to narrative in the final paragraph of Subsection 6.4, <br />which the cover letter indicates were provided in amended narrative. However, no such <br />changes were incorporated. Please revise as stated. <br />k. Subsection 6.5.1 was revised for consistency with previous subsections, to clarify that <br />livestock grazing of the dryland pasture areas was not planned during the liability period. <br />We have an additional request regarding Subsection 6.5.1. The narrative states that <br />interseeding is a normal husbandry practice on dryland pasture, and references a July 2006 <br />NRCS letter from MRCS as documentation. The letter is provided as a text page shortly <br />following the reference. The Division previously requested that all NRCS correspondence be <br />placed in appropriate attachments, referenced in the text. Please remove the letter from the <br />text and place in an appropriate attachment, with reference in the text. In addition, please <br />specify in the text, that dryland pasture interseeding would be conducted within the first 4 <br />years of any ten -year liability period, pursuant to Rule 4.15.7(5)(g). <br />